United States of America v. Approximately $29,000.00 in U.S. Currency

Filing 8

STIPULATION and ORDER 7 signed by Judge John A. Mendez on 2/24/14 ORDERING that the time for the United States of America to file a Complaint for forfeiture is EXTENDED to 4/25/2014. (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: [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 $29,000.00 IN U.S.
CURRENCY,

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2:13-MC-00077-JAM-EFB
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 claimant Andre R.

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

On or about May 1, 2013, claimant Andre R. Logan filed a claim in the administrative

21 forfeiture proceeding with the U.S. Drug Enforcement Administration with respect to the Approximately
22 $29,000.00 in U.S. Currency (“defendant currency”), which was seized on February 19, 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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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for
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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 30, 2013.
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4.

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

6 28, 2013, the time in which the United States is required to file a civil complaint for forfeiture against
7 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
8 forfeiture.
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5.

By Stipulation and Order filed October 28, 2013, the parties stipulated to extend to

10 December 27, 2013, the time in which the United States is required to file a civil complaint for forfeiture
11 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
12 subject to forfeiture.
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6.

By Stipulation and Order filed December 26, 2013, the parties stipulated to extend to

14 February 25, 2014, the time in which the United States is required to file a civil complaint for forfeiture
15 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
16 subject to forfeiture.
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7.

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

18 to April 25, 2014, the time in which the United States is required to file a civil complaint for forfeiture
19 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
20 subject to forfeiture.
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Stipulation and Order to Extend Time

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8.

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

2 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
3 alleging that the defendant currency is subject to forfeiture shall be extended to April 25, 2014.
4 Dated: 2/24/14

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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10 Dated: 2/24/14
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/s/ Richard R. Johnson
RICHARD R. JOHNSON
Attorney for claimant Andre R. Logan

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(Authorized by phone)

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IT IS SO ORDERED.

15 Dated: 2/24/2014
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/s/ John A. Mendez____________
JOHN A. MENDEZ
United States District Court Judge

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Stipulation and Order to Extend Time