United States of America v. Approximately $5,550.00 in U.S. Currency

Filing 2

STIPULATION and ORDER 1 Stipulation and Proposed Order signed by Judge Lawrence K. Karlton on 3/19/13: The deadline by which the United States is required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture is extended to May 20, 2013. (Kastilahn, A)

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4 BENJAMIN B. WAGNER United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 5 Attorneys for the United States 1 2 3 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 14 v. APPROXIMATELY $5,550.00 IN U.S. CURRENCY, 15 2:13-MC-00022-LKK-CKD STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE Defendant. 16 17 18 It is hereby stipulated by and between the United States of America by and through its 19 undersigned counsel and claimant Jayne Musser (“claimant”), in pro per, as follows: 20 1. On or about December 19, 2012, claimant Jayne Musser filed a claim in the 21 administrative forfeiture proceedings with the United States Postal Inspection Service with respect to the 22 Approximately $5,550.00 in U.S. Currency (hereafter “defendant currency”), which was seized on 23 September 28, 2012. 24 2. The United States Postal Inspection Service 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 claimant has filed a claim to the defendant currency as required by law in the administrative 28 forfeiture proceeding. 1 Stipulation and Order to Extend Time 1 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 19, 2013. 6 4. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to May 7 20, 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. 10 6. 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 May 20, 2013. 13 Dated: 3/15/2013 BENJAMIN B. WAGNER United States Attorney 14 15 16 By: 17 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney 18 19 20 21 Dated: 3/14/13 22 /s/ Jayne Musser JAYNE MUSSER In Pro Per 23 (Signature retained by attorney) 24 25 IT IS SO ORDERED 26 Dated: March 19, 2013 27 28 2 Stipulation and Order to Extend Time

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