USA v. Approximately $538,155.00 seized from ING Direct checking account # 156773818 et al

Filing 11

STIPULATION and ORDER signed by Judge John A. Mendez on 6/27/14. Joint status report due 8/29/14. (Manzer, C)

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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,
Plaintiff,

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2:14-CV-01048-JAM-AC

v.
APPROXIMATELY $538,155.00 SEIZED FROM
ING DIRECT CHECKING ACCOUNT #
156773818,

UNITED STATES’ REQUEST TO
EXTEND THE DEADLINE TO
FILE JOINT STATUS REPORT
AND ORDER

2011 FERRARI CALIFORNIA CONVERTIBLE,
VIN: ZFF65 LJA0B 01766 22, NEW JERSEY
LICENSE PLATE: NOTOUCH,
2011 AUDI A5 CONVERTIBLE, VIN:
WAULFAFH9BN009524, NEW JERSEY
LICENSE PLATE: W98ARP,
2013 BLUE PORSCHE PANAMERA, VIN:
WPOAB2A71DL060573, NEW JERSEY
LICENSE PLATE: 2012ROJ, and
APPROXIMATELY $10,002.00 IN U.S.
CURRENCY,
Defendants.

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The United States requests that the Court continue the deadline to file a

27 Joint Status Report from June 27, 2014 to August 29, 2014.
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United States’ Request to Extend the Deadline
to File Joint Status Report and Order

Introduction

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On April 28, 2014, the United States filed a civil forfeiture complaint against the

3 above-captioned assets (“defendant assets”) based on their alleged involvement in
4 violations of federal law. All known potential claimants to the defendant assets have
5 signed stipulations forfeiting their interest in the defendant assets. Additionally, public
6 notice on the official internet government forfeiture site, www.forfeiture.gov, began on
7 May 7, 2014, and ran for thirty consecutive days, as required by Rule G(4)(a)(iv)(C) of
8 Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions. A
9 Declaration of Publication was filed on June 26, 2014.
Good Cause

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

12 assets. All known potential claimants have stipulated to the forfeiture of the defendant
13 assets. To date, no party has filed a claim or answer in this case. The United States
14 intends to file a Request for Final Judgment of Forfeiture along with the executed
15 stipulations once the publication time has passed.
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For these reasons, the United States seeks to continue the deadline to file a Joint

17 Status Report from June 27, 2014 to August 29, 2014, or to another date the Court deems
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19 Dated: 6/26/14
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By:

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

ORDER
The Court finds that there is good cause to extend the deadline to file a joint status
report in this case from June 27, 2014 to August 29, 2014.
IT IS SO ORDERED.
Dated: 6/27/2014

/s/ John A. Mendez_________
JOHN A. MENDEZ
United States District Judge

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United States’ Request to Extend the Deadline
to File Joint Status Report and Order