United States of America v. Approximately 164,020.00 in U.S. Currency

Filing 31

STIPULATION AND ORDER FOR DISMISSAL WITH PREJUDICE signed by Judge John A. Mendez on 12/30/14. The United States shall take all reasonable steps to return the defendant currency to the claimants within thirty days after the date of entry of this Order. The Court enters this Certificate of Reasonable Cause pursuant to 28 U.S.C. § 2465, that there was reasonable cause for the commencement of this forfeiture action. CASE CLOSED.(Mena-Sanchez, L)

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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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2:14-CV-00400-JAM-DAD

Plaintiff,
v.
APPROXIMATELY $164,020.00 IN U.S.
CURRENCY,

STIPULATION AND ORDER FOR
DISMISSAL WITH PREJUDICE;
CERTIFICATE OF REASONABLE
CAUSE

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Defendant.
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It is hereby stipulated by and between the United States of America and claimants Brian

19 Corry Robinson and Kimberly Santiago-Robinson (collectively “Claimants”), by and through their
20 respective counsel of record (the “Stipulation”), as follows:
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1.

The defendant approximately $164,020.00 in U.S. Currency (“defendant currency”) is

22 the only named defendant in the above entitled action.
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2.

The only parties who have filed claims in this action are Brian Corry Robinson and

24 Kimberly Santiago-Robinson.
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3.

The parties to this Stipulation agree that defendant Antelope Property shall be

26 dismissed with prejudice pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure.
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4.

The parties are to bear their own costs and attorney fees.

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5.

For purposes of effectuating this stipulation and dismissal, the parties do not contest
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Stipulation and Order for Dismissal

1 there was probable cause for the commencement of this forfeiture action, and the Court may enter a
2 Certificate of Reasonable Cause pursuant to 28 U.S.C. § 2465.
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6.

The United States shall take all reasonable steps to return the defendant currency to

4 the claimants within thirty days after the date of entry of this Order.
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6 Dated:

12/23/2014

BENJAMIN B. WAGNER
United States Attorney

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By:

/s/
__________________
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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/s/____________________________
DAVID M. MICHAEL
Attorney for Claimants

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IT IS SO ORDERED.

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CERTIFICATE OF REASONABLE CAUSE

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Based upon the allegations set forth in the Complaint for Forfeiture In Rem filed December

19 20, 2010, and the Stipulation for Dismissal With Prejudice filed herewith, the Court enters this
20 Certificate of Reasonable Cause pursuant to 28 U.S.C. § 2465, that there was reasonable cause for
21 the commencement of this forfeiture action.
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23 Dated: 12/30/2014

/s/ John A. Mendez____________
JOHN A. MENDEZ
United States District Court Judge

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Stipulation and Order for Dismissal