United States of America v. $47,920.00 In U.S. Currency

Filing 25

CONSENT JUDGMENT OF FORFEITURE by Judge Stephen V. Wilson Related to: Stipulation for Judgment, Stipulation to Set Aside Default, 23 . The defendant currency was seized from Potential Claimant, Raul Samano Ramirez, and he has agreed to the forf eiture of $25,920.00 of the $47,920.00 in U.S. Currency. The Court, having considered the stipulation of the parties, and good cause appearing therefor, HEREBY ORDERS, ADJUDGES AND DECREES: The government has given and published notic e of this action as required by law, including Rule G of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rules of Civil Procedure, and the Local Rules of this Court. Potential Claimant, from whom the de fendant currency was seized, has agreed to forfeit $25,920.00. The proposed judgment further provides that $22,000.00 of the defendant currency shall be returned to Ramirez, without interest, and shall be paid to Ramirez no later than forty-five days after the date the Judgment is entered, or the date Ramirez provides the information described below, whichever is later. (MD JS-6. Case Terminated) (mrgo)

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CLERK, U.S. DISTRICT COURT

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JU. I 12018

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. I rwL UIST ICT OF
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BY
N.,A

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UNITED STATES DISTRICT COURT
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FOR THE CENTRAL DISTRICT OF CALIFORNIA
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iTNITED STATES OF AMERICA,

No. CV 17-06725-SVW(ASx)

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Plaintiff,
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CONSENT JUDGMENT
OF FORFEITURE

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$47,920.00 IN U.S. CURRENCY,
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Defendant.
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Plaintiff and Potential Claimant Raul Samano Ramirez("Ramirez") have made a

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stipulated request for the entry of this Consent Judgment, resolving this action in its

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entirety. The defendant currency was seized from Potential Claimant, and he has agreed

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to the forfeiture of $25,920.00 ofthe $47,920.00 in U.S. Currency. Notice was given

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and published in accordance with law. The government has not received any claims or

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answers, and the time for filing claims and answers has expired.

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The Court, having considered the stipulation ofthe parties, and good cause
appearing therefor, HEREBY ORDERS,ADJUDGES AND DECREES:
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The government has given and published notice ofthis action as required by

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law, including Rule G ofthe Supplemental Rules for Admiralty or Maritime Claims and

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Asset Forfeiture Actions, Federal Rules of Civil Procedure, and the Local Rules of this

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Court. Potential Claimant, from whom the defendant currency was seized, has agreed to

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forfeit $25,920.00. The government has not received any claims or answers, and the time

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f filing claims and answers has expired. This Court has jurisdiction over the parties to
or

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this judgment and the defendant currency. Any potential claimants to the defendant

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currency other than Ramirez are deemed to have admitted the allegations of the

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complaint. Nothing in this consent judgment is intended or should be interpreted as an

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admission of wrongdoing by Potential Claimant Ramirez, nor should this consent

7 judgment be admitted in any criminal proceeding against Ramirez to prove any of the
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acts relied upon to establish reasonable cause for the seizure of the defendant currency.
2.

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The proposed judgment further provides that $22,000.00 ofthe defendant

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currency shall be returned to Ramirez, without interest, and shall be paid to Ramirez no

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later than forty-five days after the date the Judgment is entered, or the date Ramirez

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provides the information described below, whichever is later.

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3.

If the United States elects to make the payment ofthe $22,000.00 by check,

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the check shall be payable to the "Richard E. Nahigian client trust account", and mailed

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to Raul Samano Ramirez in care of his attorney, Richard E. Nahigian, 1122 East Green

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Street, Pasadena, California 91106. If the United States elects to make the payment by

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wire transfer, the funds shall be wire transferred to the Richard E. Nahigian Client Trust

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Account. Claimant agrees to provide the necessary bank account information for the

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trust account and his personal identifiers upon request from the United States.
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The remaining $25,920.00 ofthe defendant.currency shall be forfeited to

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the United States, together with all interest earned by the government on the total amount

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of defendant currency, and no other right, title, or interest shall exist therein.

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5.

The court finds that there was reasonable cause for the seizure ofthe

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defendant currency and the institution of this action. This judgment constitutes a

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

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6.

Each ofthe parties shall bear its own fees and costs in connection with the

seizure ofthe defendant currency and this action.

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DATED:

,2018
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~ Prepared by:

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NICOLA T. HANNA
United States Attorney
LAWRENCE S. MIDDLETON
Assistant United States Attorney
Chief, Criminal Division
STEVEN R. WELK
Assistant United States Attorney
Chief, Asset Forfeiture Section

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/s/Michael R. Sew Hov
MICHAEL R. SEW HOY

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Assistant United States Attorney
Asset Forfeiture Section

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