United States of America v. Approximately $27,353.00 in U.S. Currency

Filing 12

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 12/16/2013 ORDERING that the deadline for the United States to file a complaint for forfeiture and/or obtain an indictment shall be EXTENDED to 1/16/2014. (Donati, J)

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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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2:13-MC-00064-TLN-KJN
STIPULATION AND ORDER
EXTENDING TIME FOR FILING A
COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

v.
APPROXIMATELY $27,353.00 IN U.S.
CURRENCY,

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Defendant.

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It is hereby stipulated by and between the United States of America and claimant Alen Alesevic

19 (“claimant”), by and through their respective counsel, as follows:
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1.

On or about April 4, 2013, claimant Alen Alesevic filed a claim in the administrative

21 forfeiture proceeding with the U.S. Drug Enforcement Administration with respect to the Approximately
22 $27,353.00 in U.S. Currency (hereafter “defendant currency”), which was seized on February 12, 2013.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

24 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
25 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other
26 than claimant has filed a claim to the defendant currency as required by law in the administrative
27 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 was July 3, 2013.
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4.

By Stipulation and Order filed July 2, 2013, the parties stipulated to extend to August 2,

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

By Stipulation and Order filed July 31, 2013, the parties stipulated to extend to August

11 23, 2013, the time in which the United States is required to file a civil complaint for forfeiture against
12 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
13 forfeiture.
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6.

By Stipulation and Order filed August 22, 2013, the parties stipulated to extend to

15 September 23, 2013, the time in which the United States is required to file a civil complaint for
16 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
17 currency is subject to forfeiture.
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7.

By Stipulation and Order filed September 19, 2013, the parties stipulated to extend to

19 November 22, 2013, the time in which the United States is required to file a civil complaint for
20 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
21 currency is subject to forfeiture.
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8.

By Stipulation and Order filed November 21, 2013, the parties stipulated to extend to

23 December 17, 2013, the time in which the United States is required to file a civil complaint for forfeiture
24 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
25 subject to forfeiture.
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9.

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

27 to January 16, 2014, the time in which the United States is required to file a civil complaint for forfeiture
28 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
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Stipulation and Order to Extend Time
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1 subject to forfeiture.
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10.

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

3 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
4 alleging that the defendant currency is subject to forfeiture shall be extended to January 16, 2014.
5 Dated: 12/13/13

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: 12/13/13
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/s/ Justin L. Ward
JUSTIN L. WARD
Attorney for claimant
Alen Alesevic

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(Authorized by phone)

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IT IS SO ORDERED.

16 Dated: December 16, 2013
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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time