United States of America v. Approximately $16,280.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 3/15/13 extending time for filing a complaint or to obtain indictment to June 18, 2013.(Kaminski, H)

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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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v.
APPROXIMATELY $16,280.00 IN U.S.
CURRENCY,

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2:13-MC-00021-GEB-DAD
STIPULATION AND ORDER
EXTENDING TIME FOR FILING
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 claimants Scott T. J.

19 Dorner and Martine A. Dijkstra (“claimants”), by and through their respective counsel, as follows:
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1.

On or about December 20, 2012, claimants Scott T. J. Dorner and Martine A. Dijkstra

21 filed claims in the administrative forfeiture proceeding with the Federal Bureau of Investigation with
22 respect to the Approximately $16,280.00 in U.S. Currency (hereafter “defendant currency”), which was
23 seized on September 22, 2012.
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2.

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

25 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
26 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other
27 than claimants has filed a claim to the defendant currency as required by law in the administrative
28 forfeiture 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 proceeding, unless the court extends the deadline for good cause shown or by agreement of the
5 parties. That deadline is March 20, 2012.
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4.

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

7 18, 2013, the time in which the United States is required to file a civil complaint for forfeiture against
8 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
9 forfeiture.
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5.

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

11 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
12 alleging that the defendant currency is subject to forfeiture shall be extended to June 18, 2013.
13 Dated: 3/15/2013

BENJAMIN B. WAGNER
United States Attorney

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

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Dated: 3/14/2013
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/s/ Michael J.Shambrook
MICHAEL J. SHAMBROOK
Attorney for claimants
Scott T. J. Dorner and
Martine A. Dijkstra

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(Signature authorized by telephone)
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IT IS SO ORDERED.

25 Dated: 3/15/13
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UNITED STATES DISTRICT JUDGE

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Stipulation and Order to Extend Time