ECHASTAINE
LAW OFFICE

2377 Gold Meadow Way, Suite 100 Counselors at Law
Gold River, CA 95670 Michael Chasmine
(916) 9327-50 Negad Zakv

June 28, 20 6

City of Rohnerr Park Police Department
500 City Center Drive

Rohnert Park, CA 94928

[Certified mail]

Re' Lucas Serafine
Notice of Discrepancy in Accounting of Seized Assets

To Whom It May Concern'

Our office has been retained by Mr Lucas Serafine to represent him
regarding any charges that might arise from a traffic stop on March 10,
2016, including recover of assets Please allow this letter to serve as a notice
of discrepancy in the accounting of the assets (in currency) seized by
your officers from the vehicle in which Mr Serafine was traveling

Mr Serafine was cited and released by Officer Brendon "Jacy" Tatum ofthe
Rohnert Park Police Department on March 10, 2016 The citation alleged a
violation of Health and Safety Code 1 1370 6(a) Officer Tatum seized
$132,000 00 in cash from the vehicle, in addition to a cellphone and
numerous financial documents

The cash was seized by Officer Tatum in its entirety; none ofit was remitted
to Mr Serafine or to the other occupant of the vehicle that Mr Serafine was
traveling with The cash was not properly inventoried, was not counted out
in front of another officer and Mr Serafine was Provided a receipt for
the cash taken

Thereafter, our office sent multiple requests and ultimately received a
"receipt" from the City of Rohnert ParkgCity l-lall purporting to document
the amount of cash recovered and disclosed by Officer Tatum from the
vehicle Mr Serafine was traveling in on the date of his arrest The amounts
reflected on the receipt were $49,900 00, $30,020 00, and $42,000 00,

 Page 2

May 29, 2018

totaling $121,920.00 (See Attachment). This recorded amount demonstrates
a discrepancy of approximately $10,080.00 that was recovered from the
vehicle that Mr. Serafine was traveling in.
It is our position that the remaining $10,080.00 is not in the
possession of any party other than the City of Rohnert Park or, more
specifically, the City of Rohnert Park Police Department. Accordingly,
either the receipt inaccurately records the $132,000.00 seized by Officer
Tatum or the unaccounted for $10,080.00 remain unaccounted for by your
department and in the possession of individuals within your department.
Please review your records and correct this discrepancy.
We look forward to your response.

Respectfully,
Michael Chastaine
Attorney at Law