UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
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UNITED STATES OF AMERICA )
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Plaintiff, )
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v. ) Civil Action No. 21-0305 (PLF)
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ALL PETROLEUM-PRODUCT CARGO )
ABOARD THE ACHILLEAS WITH )
INTERNATIONAL MARITIME )
ORGANIZATION NUMBER 9398072, )
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Defendant In Rem, )
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FUJAIRAH INTERNATIONAL OIL & )
GAS CORPORATION, )
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Claimant, )
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- and - )
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STEVEN M. GREENBAUM, et al., )
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Claimants. )
____________________________________)
MEMORANDUM OPINION AND ORDER
Pending before the Court is movant Billy G. Asemani’s Motion to Intervene
Pursuant to Rule 24 of the F.R.C.P. (“Mot.”) [Dkt. No. 80]. Mr. Asemani, proceeding pro se,
seeks to intervene as a claimant in this forfeiture action pursuant to Rule 24 of the Federal Rules
of Civil Procedure. A third party claiming an interest in the defendant property in a civil
forfeiture action must proceed in accordance with the Supplemental Rules for Admiralty or
Maritime Claims and Asset Forfeiture Actions (the “Supplemental Rules”). See United States v. All Assets Held at Bank Julius Baer & Co., 743 F. Supp. 3d 204, 217 (D.D.C. 2024). Because
Mr. Asemani has not complied with the Supplemental Rules, the Court will deny his motion.
I. BACKGROUND
This in rem forfeiture action arises out of a federal investigation into the
transportation and sale of oil products for the benefit of sanctioned entities of the Islamic
Republic of Iran. See United States’ Verified Amended Complaint for Forfeiture In Rem [Dkt.
No. 61] ¶ 1. At issue is oil cargo formerly aboard a vessel called the M/T Achilleas (the
“Defendant Property”), which “originated from oil terminals in Iran.” Id. The United States
alleges that the petroleum cargo “is subject to seizure and forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(G)(1).” Id. ¶ 2.
On May 21, 2026, Mr. Asemani moved to intervene in this civil forfeiture action
as an “interested party” pursuant to Rule 24 of the Federal Rules of Civil Procedure. Mot.; see
FED. R. CIV. P. 24. He suggests that his interest in this case arises from a separate action that he
filed in the Southern District of Florida. See Mot. (citing Asemani v. Office of Foreign Assets
Control, Civil Action No. 26-14051 (S.D. Fla.)). Magistrate Judge Maynard dismissed that
action without prejudice for failure to state a claim about a month before Mr. Asemani filed his
motion in this Court. See United States’ Opposition to Billy G. Asemani’s Motion to Intervene
(“Opp.”) [Dkt. No. 81] at Ex. 1; Order, Asemani v. Office of Foreign Assets Control, Civil
Action No. 26-14051, at 5-9 (S.D. Fla. Apr. 29, 2026), Dkt. No. 16. Mr. Asemani states that he
will address his purported interest in the Defendant Property through a memorandum that he will
file “[a]t a follow-up juncture.” Mot.
The United States filed an opposition to Mr. Asemani’s motion on June 17, 2026.
See Opp. As of the date of this Memorandum Opinion and Order, Mr. Asemani has not filed a
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reply in further support of his motion. Mr. Asemani also has not filed an answer to the United
States’ verified complaint.
II. LEGAL STANDARD
Civil forfeiture actions “are governed by the procedures set forth in 18 U.S.C.
§ 983 and the Supplemental Rules . . . , a subset of the Federal Rules of Civil Procedure.”
United States v. All Assets Held at Bank Julius Baer & Co., 743 F. Supp. 3d at 217. “When the
government files a complaint for forfeiture, ‘any person claiming an interest in the seized
property may file a claim asserting such person’s interest in the property in the manner set forth
in the Supplemental Rules.” Id. (quoting 18 U.S.C. § 983(a)(4)(A)); see FED. R. CIV. P. SUPP. R.
G(5)(a)(i). “Courts generally expect claimants to adhere strictly to” the requirements of the
Supplemental Rules. United States v. All Assets Held at Bank Julius Baer & Co., 743 F.
Supp. 3d at 217.
Pursuant to Supplemental Rule G(5), a claimant asserting “an interest in the
defendant property” must file a claim that: (1) “identif[ies] the specific property claimed”;
(2) “identif[ies] the claimant and state[s] the claimant’s interest in the property”; (3) “[is] signed
by the claimant under penalty of perjury;” and (4) “[is] served on the government attorney
designated under Rule G(4)(a)(ii)(C) or (b)(ii)(D).” FED. R. CIV. P. SUPP. R. G(5)(a). In
addition, “[a] claimant must serve and file an answer to the complaint or a motion under Rule 12
within 21 days after filing the claim.” FED. R. CIV. P. SUPP. R. G(5)(b). “The only way for a
third party to intervene in a civil forfeiture case is to file a claim to the property and an answer to
the Government’s complaint pursuant to [Supplemental] Rule G(5).” United States v. All Assets
Held at Bank Julius Baer & Co., 743 F. Supp. 3d at 217 (alteration in original) (quoting Stefan
D. Cassella, ASSET FORFEITURE LAW IN THE UNITED STATES § 7-13(a), at 371 (3d ed. 2022)); see
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also United States v. Fifty-Three Virtual Currency Accts., Civil Action No. 20-2227 (RC), 2025
WL 2732705, at *3 (D.D.C. Sep. 25, 2025) (“To contest forfeiture, a claimant must file a
verified claim and an answer pursuant to Supplemental Rule G(5).”). The verified claim and
answer establish a claimant’s statutory standing to contest forfeiture, and a party who does not
file either may not participate in the litigation. See United States v. Fifty-Three Virtual Currency
Accts., 2025 WL 2732705, at *3.
III. DISCUSSION
Mr. Asemani seeks to intervene in this action under Rule 24 of the Federal Rules
of Civil Procedure. See Mot. As noted above, however, “[t]he only way for a third party to
intervene in a civil forfeiture case is to file a claim to the property and an answer to the
Government’s complaint pursuant to [Supplemental] Rule G(5).” United States v. All Assets
Held at Bank Julius Baer & Co., 743 F. Supp. 3d at 217. “[P]utative claimants have no separate
right to intervene under Rule 24 of the Federal Rules of Civil Procedure.” Id.; see also Minute
Order, United States v. $12,973,529 in Funds on Deposit at the U.S. Treasury, Account No.
Xxxx1883, Civil Action No. 26-0802 (DLF) (D.D.C. June 1, 2026) (denying a motion to
intervene under Rule 24 because “Rule G(5)(a), which sets forth the requirements for potential
claims, does not contemplate motions to intervene as a plaintiff”).
Even construing Mr. Asemani’s motion to intervene—favorably to him—as a
claim under Supplemental Rule G(5), that claim does not comply with the Supplemental Rules in
at least two ways. First, Mr. Asemani does not “assert an interest in the specific property named
as a defendant.” United States v. Fifty-Three Virtual Currency Accts., 2025 WL 2732705,
at *3; see FED. R. CIV. P. SUPP. R. G(5)(a)(i)-(ii). Instead, Mr. Asemani’s one-page motion
merely asserts that he will address “his claim to a portion of the properties that are the subject of
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the forfeiture request” at a “follow-up juncture.” Mot. To be sure, “where claimants are
proceeding pro se, courts may excuse some minor procedural failings so long as ‘the underlying
goals of’ the Supplemental Rules ‘are not frustrated.’” United States v. All Assets Held at Bank
Julius Baer & Co., 664 F. Supp. 2d 97, 102 (D.D.C. 2009) (quoting United States v. Funds from
Prudential Secs., 300 F. Supp. 2d 99, 104 (D.D.C. 2004)). But as the government correctly
points out, Mr. Asemani’s “failure to assert any interest in the defendant property is not a minor
procedural error—it is a material deficiency frustrating the purpose of [Supplemental] Rule
(G)(5).” Opp. at 5. “[T]he less stringent standard for pro se litigants does not allow them to
simply disregard the applicable [rules].” United States v. All Assets Held at Bank Julius Baer &
Co., 664 F. Supp. 2d at 102 (quoting United States v. Funds from Prudential Secs., 362 F.
Supp. 2d 75, 82 (D.D.C. 2005)).
Second, Mr. Asemani has not filed an answer to the verified complaint. See
United States v. All Assets Held at Bank Julius Baer & Co., 664 F. Supp. 2d at 102. Pursuant to
Supplemental Rule G(5), Mr. Asemani was required to file an answer or a motion under Rule 12
of the Federal Rules of Civil Procedure “within 21 days after filing the claim.” FED. R. CIV. P.
SUPP. R. G(5)(b). Mr. Asemani filed his claim on May 21, 2026, see Mot., meaning that he was
required to file an answer or Rule 12 motion on or before June 11, 2026. He has not done so. As
this Court previously has explained, such a “failing [is] dispositive,” even when the putative
claimant is proceeding pro se. United States v. All Assets Held at Bank Julius Baer & Co., 664
F. Supp. 2d at 102.
In sum, Mr. Asemani has failed to comply with the requirements of Supplemental
Rule G, which provides the exclusive means of contesting forfeiture. The Court therefore will
deny his motion to intervene.
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