USA v. Approx. $25,000.00 in U.S. Currency

Filing 6

STIPULATION and ORDER Extending Time for Filing a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture signed by District Judge Jennifer L. Thurston on 7/29/2022. (Sant Agata, S)

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PHILLIP A. TALBERT
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

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Attorneys for the United States

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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,

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Plaintiff,

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v.

CASE NO. 1:22-MC-00035-JLT
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $25,000.00 IN
U.S. CURRENCY,

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Defendant.
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It is hereby stipulated by and between the United States of America and potential claimant Jesus

18 Pedro Maldonado Ceja (“claimant”), by and through their respective counsel, as follows:
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1.

On or about December 1, 2021, claimant Maldonado Ceja filed a claim in the

20 administrative forfeiture proceedings with the Federal Bureau of Investigation with respect to the
21 Approximately $25,000.00 in U.S. Currency (hereafter “defendant currency”), which was seized on
22 September 2, 2021.
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2.

The Federal Bureau of Investigation has sent the written notice of intent to forfeit required

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

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3.

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

2 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
3 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
4 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the
5 parties. That deadline was March 1, 2022.
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4.

By Stipulation and Order filed March 4, 2022, the parties stipulated to extend to May 2,

7 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
8 defendant property and/or to obtain an indictment alleging that the defendant property is subject to
9 forfeiture.
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5.

By Stipulation and Order filed April 26, 2022, the parties stipulated to extend to July 31,

11 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
12 defendant property and/or to obtain an indictment alleging that the defendant property is subject to
13 forfeiture.
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6.

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

15 to September 29, 2022, the time in which the United States is required to file a civil complaint for
16 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
17 currency is subject to forfeiture.
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7.

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

19 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
20 alleging that the defendant currency is subject to forfeiture shall be extended to September 29, 2022.
21 Dated: July 29, 2022

PHILLIP A. TALBERT
United States Attorney

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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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26 Dated: July 28, 2022
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/s/ Robert L. Forkner
ROBERT L. FORKNER
Attorney for potential claimant
Jesus Pedro Maldonado Ceja
(As approved by email on 7/28/22)
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Stipulation and Order to Extend Time

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IT IS SO ORDERED.
Dated:

July 29, 2022

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Stipulation and Order to Extend Time