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

Filing 8

STIPULATION and ORDER signed by Judge John A. Mendez on 12/13/13 ORDERING the parties agree that the deadline by which the United States shall be 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 shall be extended to January 13, 2014. (Becknal, R)

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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v.
APPROXIMATELY $97,980.00 IN U.S.
CURRENCY,

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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

Defendant.

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It is hereby stipulated by and between the United States of America and claimant Joshua Bowen

19 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 respect to
22 the Approximately $97,980.00 in U.S. Currency (hereafter “defendant currency”), which was seized on
23 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 the
26 defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a
27 claim to the defendant currency as required by law in the administrative 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 proceedings, unless the court extends the deadline for good cause shown or by agreement of the
5 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 October

7 15, 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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5.

By Stipulation and Order filed October 11, 2013, the parties stipulated to extend to

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

By Stipulation and Order filed November 14, 2013, the parties stipulated to extend to

15 December 13, 2013, the time in which the United States is required to file a civil complaint for forfeiture
16 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
17 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

19 to January 13, 2014, the time in which the United States is required to file a civil complaint for forfeiture
20 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
21 subject to forfeiture.
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8.

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

23 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 January 13, 2014.
3 Dated: 12/12/13

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: 12/12/13
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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

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14 Dated: 12/13/2013
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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