USA v. Approximately $66,379.31 in U.S. Currency seized from Golden One Credit Union money market account number 11321409-2 et al

Filing 3

STIPULATION and ORDER signed by Judge William B. Shubb on 10/11/2012 ORDERING the United States to file a Complaint for Forfeiture against the defendant funds and/or to obtain an Indictment by 12/19/2012. (Michel, G)

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BENJAMIN B. WAGNER
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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2:12-MC-00081-WBS-KJN
STIPULATION AND ORDER
EXTENDING TIME FOR FILING
A COMPLAINT FOR
FORFEITURE AND/OR TO
OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

v.
APPROXIMATELY $66,379.31 IN U.S.
CURRENCY SEIZED FROM GOLDEN
ONE CREDIT UNION ACCOUNT
NUMBER 1321409-2, AND
APPROXIMATELY $3,905.03 IN U.S.
CURRENCY SEIZED FROM GOLDEN
ONE CREDIT UNION ACCOUNT
NUMBER 909462-0,
Defendants.

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It is hereby stipulated by and between the United States of America and claimant Abbas M.

22 Tourzani, in propria persona (“claimant”), as follows:
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1.

On or about July 26, 2012, claimant Abbas M. Tourzani filed a claim, in the

24 administrative forfeiture proceedings, with the Internal Revenue Service - Criminal Investigation
25 with respect to the Approximately $66,379.31 in U.S. Currency seized from Golden One Credit
26 Union account number 1321409-2 and Approximately $3,905.0331 in U.S. Currency seized from
27 Golden One Credit Union account number 909462-0 (hereafter “defendant funds”), which were
28 seized on June 19, 2012.
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Stipulation and Order to Extend Time

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2.

The Internal Revenue Service - Criminal Investigation has sent the written notice of

2 intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has
3 expired for any person to file a claim to the defendant funds under 18 U.S.C. § 983(a)(2)(A)-(E), and
4 no person other than the claimant has filed a claim to the defendant funds as required by law in the
5 administrative forfeiture proceeding.
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3.

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

7 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant
8 funds are subject to forfeiture within ninety days after a claim has been filed in the administrative
9 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement
10 of the parties. That deadline is October 24, 2012.
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4.

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

12 extension to December 19, 2012, the time in which the United States is required to file a civil
13 complaint for forfeiture against the defendant funds and/or to obtain an indictment alleging that the
14 defendant funds are subject to forfeiture.
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5.

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

16 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
17 alleging that the defendant funds are subject to forfeiture shall be extended to December 19, 2012.
18 Dated:

10/11/12

BENJAMIN B. WAGNER
United States Attorney

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

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22 Dated:

10/11/12

/s/ Abbas M. Tourzani
ABBAS M. TOURZANI
Claimant in propria persona
(Authorized via telephone on 10/11/12)

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IT IS SO ORDERED.
Dated: October 11, 2012

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Stipulation and Order to Extend Time