United States of America v. Approximately $30,640.00 in U.S. Currency

Filing 12

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 6/24/14: The Court finds that there is good cause to extend the deadline to file a joint status report in this case from May 27, 2014 to July 28, 2014. (Kaminski, H)

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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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2:14-CV-00712-MCE-CKD

v.
APPROXIMATELY $30,640.00 IN U.S.
CURRENCY,

UNITED STATES’ REQUEST TO
EXTEND THE DEADLINE TO
SUBMIT A JOINT STATUS
REPORT FROM MAY 27, 2014 TO
JULY 28, 2014; PROPOSED
ORDER

Defendant.

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The United States submits the following Request to Extend the Deadline to file a

19 Joint Status Report from May 27, 2014 to July 28, 2014.
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Introduction
On March 18, 2014, the United States filed a civil forfeiture complaint against the

23 above-captioned currency (“defendant currency”), based on its involvement in federal drug
24 law violations. All known potential claimants to the defendant currency were served in a
25 manner consistent with Dusenbery v. United States, 534 U.S. 161, 168 (2002) and the
26 applicable statutory authority. Additionally, public notice on the official internet
27 government forfeiture site, www.forfeiture.gov, began on March 21, 2014, and ran for
28 thirty consecutive days, as required by Rule G(4)(a)(iv)(C) of Supplemental Rules for
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United States’ Request to Extend the Deadline
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to Submit a Joint Status Report

1 Admiralty or Maritime Claims and Asset Forfeiture Actions. A Declaration of Publication
2 was filed on April 21, 2014.
Good Cause

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The United States has diligently pursued its forfeiture case against the defendant

5 currency and noticed all known potential claimants as required by the Supplemental
6 Rules governing forfeiture cases. To date, no party has filed a claim or answer in this
7 case. On May 22, 2014, the United States filed a Request for Clerk’s Default against
8 potential claimant Neal Alan Beauregard and intends to draft a motion for default
9 judgment and final judgment of forfeiture.
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Thus, there is good cause to extend the deadline to file a joint status report in this

11 case from May 27, 2014 to July 28, 2014, or to a date the Court deems appropriate.
12 Dated:

5/22/14

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BENJAMIN B. WAGNER
United States Attorney
/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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ORDER

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The Court finds that there is good cause to extend the deadline to file a joint status

20 report in this case from May 27, 2014 to July 28, 2014.
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IT IS SO ORDERED.

22 Dated: June 24, 2014
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United States’ Request to Extend the Deadline
to Submit a Joint Status Report