United States of America v. 25,931.00 in U S Currency

Filing 10

CONSENT JUDGMENT OF FORFEITURE by Judge Manuel L. Real 9 . ( MD JS-6. Case Terminated ) (pj)

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ANDRÉ BIROTTE JR.
United States Attorney
ROBERT E. DUGDALE
Assistant United States Attorney
Chief, Criminal Division
STEVEN R. WELK
Assistant United States Attorney
Chief, Asset Forfeiture Section
KATHARINE SCHONBACHLER
Assistant United States Attorney
Asset Forfeiture Section
California Bar No. 222875
Federal Courthouse, 14th Floor
312 North Spring Street
Los Angeles, California 90012
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiff
United States of America

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UNITED STATES DISTRICT COURT
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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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UNITED STATES OF AMERICA,
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Plaintiff,
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vs.
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$25,931.00 IN U.S. CURRENCY,
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Defendant.

) NO. CV 13-1403 R (OPx)
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) CONSENT JUDGMENT OF FORFEITURE
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This action was filed on February 26, 2013.

Notice was

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given and published in accordance with law and the time for
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filing claims and answers has expired.

Potential claimant

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Antonio Bravo, Jr. (“Bravo, Jr.”) from whom the defendant
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currency was seized has not filed a claim or answer in this

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matter.

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claimant Bravo, Jr. have reached an agreement that is

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dispositive of the action.

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Jr. shall be relieved of his obligation to file a claim and

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answer.

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Consent Judgment of Forfeiture.

Notwithstanding that fact, Plaintiff and potential

Pursuant to the agreement, Bravo,

The parties hereby request that the Court enter this

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WHEREFORE, IT IS ORDERED, ADJUDGED AND DECREED:

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1.

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This Court has jurisdiction over the parties and the

subject matter of this action.
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Notice of this action has been given in accordance

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with law.

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in U.S. currency (hereinafter “defendant currency”) other than

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Bravo, Jr. are deemed to have admitted the allegations of the

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Complaint.

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sufficient to establish a basis for forfeiture.

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3.

All potential claimants to the defendant $25,931.00

The allegations set out in the Complaint are

The United States of America shall have judgment as to

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$22,041.00 of the defendant currency, plus all interest earned

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by the government on the full amount of the defendant currency,

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and no other person or entity shall have any right, title or

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interest therein.

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to dispose of said assets in accordance with law.

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4.

The United States Marshals Service is ordered

$3,890.00 of the defendant currency, without any

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interest earned by the government on the full amount of the

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defendant currency, shall be returned to Bravo, Jr. by either

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check or wire transfer.

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payment by check, the check will be payable to “Antonio Bravo,

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Jr. and Law Offices of Roger J. Rosen Client Trust Account,” and

If the United States elects to make the

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mailed to his attorney Roger J. Rosen, Esq. at the Law Offices

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of Roger J. Rosen, 1801 Avenue of the Stars, Suite 1200, Los

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Angeles, California 90067.

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the payment by wire transfer, the funds will be wire transferred

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to the Law Offices of Roger J. Rosen Client Trust Account.

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Bravo, Jr. and his attorney shall provide any and all

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information needed to process the return of these funds

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according to federal law.
5.

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If the United States elects to make

Bravo, Jr. hereby releases the United States of

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America, its agencies, agents, and officers, including employees

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and agents of the Drug Enforcement Administration, as well as

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all agents, officers, employees and representatives of any state

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or local government or law enforcement agency involved in the

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investigation or prosecution of this matter, from any and all

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claims, actions or liabilities arising out of or related to the

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seizure of the defendant currency or the prosecution of this

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action, including, without limitation, any claim for attorney’s

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fees, costs or interest which may be asserted on behalf of

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Bravo, Jr., whether pursuant to 28 U.S.C. § 2465 or otherwise.
6.

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The court finds that there was reasonable cause for

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the seizure of the defendant currency and institution of these

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proceedings.

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of reasonable cause pursuant to 28 U.S.C. § 2465.

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///

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///

This judgment shall be construed as a certificate

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The parties stipulate and request that the Motion

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for Default Judgment scheduled for July 1, 2013 be

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taken off calendar if the Court approves and

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enters this Consent Judgment.

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Dated:

June 10, 2013

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THE HONORABLE MANUEL REAL
UNITED STATES DISTRICT JUDGE

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Approved as to form and content:
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DATED: June 7, 2013

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ANDRÉ BIROTTE JR.
United States Attorney
ROBERT E. DUGDALE
Assistant United States Attorney
Chief, Criminal Division
STEVEN R. WELK
Assistant United States Attorney
Chief, Asset Forfeiture Section
/S/
KATHARINE SCHONBACHLER
Assistant United States Attorney

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Attorneys for Plaintiff
United States of America

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DATED: June 7, 2013

LAW OFFICES OF ROGER J. ROSEN

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/S/
ROGER J. ROSEN
Attorneys for Antonio Bravo, Jr.

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DATED: June 7, 2013
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/S/
Antonio Bravo, Jr.
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