United States of America v. Approximately $97,980.00 in U.S. Currency

Filing 4

STIPULATION and ORDER 3 for extension of time signed by Judge John A. Mendez on 10/10/2013. The deadline by the United States shall file a Complaint for Forfeiture is EXTENDED to 11/14/2013. (Marciel, M)

1 BENJAMIN B. WAGNER
United States Attorney
2 KEVIN C. KHASIGIAN
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
5 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-00083-JAM-DAD
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

v.
APPROXIMATELY $97,980.00 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 Joshua

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

On or about May 20, 2013, claimant Joshua Bowen Furlong filed a claim in the

21 administrative forfeiture proceedings with the Drug Enforcement Administration (“DEA”) with
22 respect to the Approximately $97,980.00 in U.S. Currency (hereafter “defendant currency”), which
23 was seized on January 10, 2013.
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2.

The DEA has sent the written notice of intent to forfeit required by 18 U.S.C. §

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

1 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

3 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
4 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
5 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement
6 of the parties. That deadline was August 16, 2013.
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4.

By Stipulation and Order filed August 9, 2013, the parties stipulated to extend to

8 October 15, 2013, the time in which the United States is required to file a civil complaint for
9 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
10 currency is subject to forfeiture.
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5.

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

12 extend to November 14, 2013, the time in which the United States is required to file a civil
13 complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that
14 the defendant currency is subject to forfeiture.
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6.

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

16 required to file a complaint for forfeiture against the defendant currency and/or to obtain an
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Stipulation and Order to Extend Time

1 indictment alleging that the defendant currency is subject to forfeiture shall be extended to
2 November 14, 2013.
3 Dated: 10/10/13

BENJAMIN B. WAGNER
United States Attorney

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By: /s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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8 Dated: 10/10/13
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/s/ John Balazs
JOHN BALAZS
Attorney for claimant Joshua Bowen Furlong
(Authorized by email)

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IT IS SO ORDERED.
Dated: 10/10/2013
/s/ John A. Mendez____________
JOHN A. MENDEZ
United States District Court Judge

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Stipulation and Order to Extend Time