United States of America v. Approximately $9,000.00 in U.S. Currency et al

Filing 57

STIPULATION AND ORDER signed by Senior Judge William B. Shubb on 12/2/2014 ORDERING the parties to file a Joint Status Report by 12/19/2014; CONTINUING the Scheduling Conference to 1/5/2015 at 02:00 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Michel, G)

1 BENJAMIN B. WAGNER
United States Attorney
2 KEVIN C. KHASIGIAN
Assistant U.S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
5 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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2:07-CV-01290-WBS-DAD

Plaintiff,
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
FILE JOINT STATUS REPORT

v.
APPROXIMATELY $9,000.00 IN U.S.
CURRENCY, and

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APPROXIMATELY $4,580.00 IN U.S.
CURRENCY,
Defendants.

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The United States and claimants Wei Jei Ma (“Ma”) and Cindy Woo (“Woo”),

20 through undersigned counsel, stipulate and request the Court continue the deadline to
21 file a Joint Status Report from November 28, 2014 to December 19, 2014.
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On June 29, 2007, the United States filed a civil forfeiture complaint against the

23 above-captioned currency (“defendant currency”) based on its alleged involvement in
24 federal drug law violations. All known potential claimants to the defendant properties
25 were served in a manner consistent with Dusenbery v. United States, 534 U.S. 161, 168
26 (2002) and the applicable statutory authority. Additionally, on July 18, 2007, the United
27 States published notice of this action in The Recorder (San Francisco and San Mateo
28 Counties) and the Inter-City Express (Alameda County), as required by Rule
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Stipulation and [Proposed] Order to Extend the
Deadline to File a Joint Status Report

1 G(4)(a)(iv)(A) of Supplemental Rules for Admiralty or Maritime Claims and Asset
2 Forfeiture Actions.
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On August 1, 2007, Wei Jei Ma and Cindy Woo filed claims alleging an interest in

4 the defendant currency, followed by their answers on August 20, 2007. No other party
5 has entered this case and the United States has provided notice to all potential claimants
6 pursuant to law.
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Ma was criminally indicted in a parallel criminal case, United States v. Wei Jei Ma,

8 2:07-CR-00025-EJG and was recently sentenced on October 6, 2014.
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In light of Ma’s recent sentencing, the parties request a continuance of the deadline

10 to file a Joint Status Report from November 28, 2014 to December 19, 2014, or to another
11 date the Court deems appropriate.
12 Dated: 11/28/14
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BENJAMIN B. WAGNER
United States Attorney
By:

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15 Dated: 11/28/14
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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
/s/ Stuart Hanlon
STUART HANLON
Attorney for Claimants
(authorized via email)

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ORDER
Pursuant to the parties’ stipulation, the Court makes the following order:
The deadline to file a Joint Status Report currently due on November 28, 2014 IS
CONTINUED to December 19, 2014.

The Scheduling Conference is continued to

January 5, 2015 at 2:00 p.m.
IT IS SO ORDERED.
Dated: December 2, 2014

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Stipulation and [Proposed] Order to Extend the
Deadline to File a Joint Status Report