USA v. Approximately $13,720.00 in U.S. Currency

Filing 2

STIPULATION and ORDER EXTENDING the United States' Time to File a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture signed by District Judge Lawrence J. O'Neill on 1/27/2014. (Sant Agata, S)

1 BENJAMIN B. WAGNER
United States Attorney
2 JEFFREY A. SPIVAK
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
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6 Attorneys for Plaintiff
United States of America
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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,
Plaintiff,

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v.

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APPROXIMATELY 13,720.00 IN U.S.
CURRENCY,

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CASE NO. 1:14-MC-00004-LJO
STIPULATION AND ORDER EXTENDING
THE UNITED STATES’ TIME TO FILE A
COMPLAINT FOR FORFEITURE AND/OR
TO OBTAIN AN INDICTMENT ALLEGING
FORFEITURE

Defendant.

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It is hereby stipulated by and between the United States of America and Claimant

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18 Aaron Brown (hereafter “Claimant”), by and through his respective attorney, as follows:
1.

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On or about October 28, 2013, Claimant filed a claim, in the administrative

20 forfeiture proceeding, with the United States Drug Enforcement Administration with
21 respect to the approximately $13,720.00 in U.S. Currency (hereafter “currency”), which
22 was seized on or about June 11, 2013.
2.

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The United States Drug Enforcement Administration sent the written notice

24 of intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties.
25 The time has expired for any person to file a claim to the currency under 18 U.S.C. §
26 983(a)(2)(A)-(E), and no person other than the Claimant has filed a claim to the currency
27 as required by law in the administrative forfeiture proceeding.
28 ///

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STIPULATION AND ORDER EXTENDING THE UNITED
STATES’ TIME TO FILE A COMPLAINT FOR FORFEITURE
AND/OR OBTAINING AN INDICTMENT ALLEGING
FORFEITURE

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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a

2 complaint for forfeiture against the currency and/or to obtain an indictment alleging that
3 the currency is subject to forfeiture within 90 days after a claim has been filed in the
4 administrative forfeiture proceedings, unless the court extends the deadline for good cause
5 shown or by agreement of the parties.
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4.

As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to

7 extend to March 25, 2014, the time in which the United States is required to file a civil
8 complaint for forfeiture against the currency and/or to obtain an indictment alleging that
9 the currency is subject to forfeiture.
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5.

Accordingly, the parties agree that the deadline by which the United States

11 shall be required to file a complaint for forfeiture against the currency and/or to obtain an
12 indictment alleging that the currency is subject to forfeiture shall be extended to March
13 25, 2014.
14 Dated: January 22, 2014

BENJAMIN B. WAGNER
United States Attorney

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By: /s/ Jeffrey A. Spivak
JEFFREY A. SPIVAK
Assistant United States Attorney

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19 Dated: January 22, 2014
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By: /s/ J. Allen Crumpler III
J. ALLEN CRUMPLER III
Attorney for Claimant Aaron Brown
(Original signature retained by attorney)

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IT IS SO ORDERED.
Dated:

/s/ Lawrence J. O’Neill

January 27, 2014

UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER EXTENDING THE UNITED
STATES’ TIME TO FILE A COMPLAINT FOR FORFEITURE
AND/OR OBTAINING AN INDICTMENT ALLEGING
FORFEITURE

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