United States of America v. Approximately $5,550.00 in U.S. Currency
Filing
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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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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
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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 $5,550.00 IN U.S.
CURRENCY,
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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.
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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:
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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.
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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.
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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 19, 2013.
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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.
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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
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By:
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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
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21 Dated: 3/14/13
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/s/ Jayne Musser
JAYNE MUSSER
In Pro Per
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(Signature retained by attorney)
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IT IS SO ORDERED
26 Dated: March 19, 2013
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Stipulation and Order to Extend Time
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