Free Answer to Complaint - District Court of California - California

Case 4:06-cv-07933-SBA

Document 15

Filed 05/18/2007

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HAROLD ROSENTHAL Attorney at Law 803 Hearst Avenue Berkeley, CA 94710 Tele: (510) 981-1800 Fax: (510) 981-1821 Attorney for Claimant HOUSHANG POURMOHAMAD

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) $80 396 IN UNITED STATES ) Defendants. ) ____________________________________) ) HOUSHANG POURMOHAMAD, ) ) Claimant. ) ____________________________________) UNITED STATES OF AMERICA, Case No. C 06-7933 MJJ HOUSHANG POURMOHAMAD'S FIFTH AMENDMENT ANSWER TO COMPLAINT FOR FORFEITURE

Claimant Houshang Pourmohamad answers the Government's Complaint for Forfeiture 17 as follows: 18 Claimant Houshang Pourmohamad is the named defendant in a criminal action entitled 19 United States v. Houshang Pourmohamad, Northern District of California, No. 4:06-CR-0055520 SBA, based upon the same acts and transactions which are the subject of the instant Complaint 21 for Forfeiture. That matter is pending trial. 22 The knowledge that Claimant Pourmohamad has concerning the facts underlying the 23 Forfeiture Complaint, and his admission or denial of any of the allegations of the Complaint, 24 could be deemed a waiver of his Fifth Amendment Privilege and could be used against him in the 25 1

Case 4:06-cv-07933-SBA

Document 15

Filed 05/18/2007

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present criminal matter. Claimant Pourmohamad therefore asserts in answer to the Complaint his privilege against self-incrimination as guaranteed by the Fifth Amendment to the United States Constitution and requests that such denial be deemed a specific denial of each and every allegation of the Complaint for Forfeiture. Claimant reserves the right to modify or supplement this Answer, with leave of Court as required, depending on further developments in the parallel criminal investigation and/or proceedings, or at a time Claimant chooses voluntarily to waive his privilege against self-incrimination, or at a time when he is compelled to answer pursuant to court order. Dated: May 18, 2007 Respectfully submitted,

__________/S/________________ HAROLD ROSENTHAL Attorney for Claimant HOUSHANG POURMOHAMAD

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