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

Filing 6

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 8/21/13 EXTENDING time for filing a complaint for forfeiture and/or to obtain an indictment alleging forfeiture. (Meuleman, 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 $27,353.00 IN U.S. CURRENCY, 15 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 Defendant. 16 17 18 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: 20 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. 23 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. 28 3. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for 1 Stipulation and Order to Extend Time 1 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant 2 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative 3 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the 4 parties. That deadline was July 3, 2013. 5 4. By Stipulation and Order filed July 2, 2013, the parties stipulated to extend to August 2, 6 2013, the time in which the United States is required to file a civil complaint for forfeiture against the 7 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 8 forfeiture. 9 5. By Stipulation and Order filed July 31, 2013, the parties stipulated to extend to August 10 23, 2013, the time in which the United States is required to file a civil complaint for forfeiture against 11 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 12 forfeiture. 13 6. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 14 to September 23, 2013, the time in which the United States is required to file a civil complaint for 15 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant 16 currency is subject to forfeiture. 17 7. Accordingly, the parties agree that the deadline by which the United States shall be 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 2 Stipulation and Order to Extend Time 1 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 2 alleging that the defendant currency is subject to forfeiture shall be extended to September 23, 2013. 3 Dated: 8/20/2013 BENJAMIN B. WAGNER United States Attorney 4 5 By: 6 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney 7 8 Dated: 8/20/2013 10 /s/ Justin L. Ward JUSTIN L. WARD Attorney for claimant Alen Alesevic 11 (Signature authorized by telephone) 9 12 13 IT IS SO ORDERED. 14 Dated: August 21, 2013 15 Troy L. Nunley United States District Judge 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Stipulation and Order to Extend Time

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