USA v. Miscellaneous Art, Jewelry, and Currency listed in Exhibit A

Filing 10

ORDER signed by Judge John A. Mendez on 6/27/14 ORDERING that the Court finds that there is good cause to extend the deadline to file a joint status report in this case from June 30, 2014 to August 29, 2014. (Becknal, R)

4

BENJAMIN B. WAGNER
United States Attorney
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

5

Attorneys for the United States

1
2
3

6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,
Plaintiff,

12
13
14
15

2:14-CV-01074-JAM-AC
UNITED STATES’ REQUEST TO
EXTEND THE DEADLINE TO
FILE JOINT STATUS REPORT
AND ORDER

v.
MISCELLANEOUS ART, JEWELRY, AND
CURRENCY LISTED IN EXHIBIT A,
Defendants.

16
17
18

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

19 Joint Status Report from June 30, 2014 to August 29, 2014.
20
21
22

Introduction
On April 30, 2014, the United States filed a civil forfeiture complaint against the

23 above-captioned assets (“defendant assets”) based on their alleged involvement in
24 violations of federal law. All known potential claimants to the defendant assets have
25 signed a stipulation forfeiting their interest in the defendant assets. Additionally, public
26 notice on the official internet government forfeiture site, www.forfeiture.gov, began on
27 May 7, 2014, and ran for thirty consecutive days, as required by Rule G(4)(a)(iv)(C) of
28
1

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

1 Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions. A
2 Declaration of Publication was filed on June 27, 2014.
Good Cause

3
4

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

5 assets. All known potential claimants have stipulated to the forfeiture of the defendant
6 assets. To date, no party has filed a claim or answer in this case. The United States
7 intends to file a Request for Final Judgment of Forfeiture along with the executed
8 stipulation once the publication time has passed.
9

For these reasons, the United States seeks to continue the deadline to file a Joint

10 Status Report from June 30, 2014 to August 29, 2014, or to another date the Court deems
11 appropriate.
12 Dated: 6/27/14
13

BENJAMIN B. WAGNER
United States Attorney
By:

14

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

15
16
ORDER

17
18

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

19 report in this case from June 30, 2014 to August 29, 2014.
20

IT IS SO ORDERED.

21 Dated: 6/27/2014
22

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

23
24
25
26
27
28
2

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

Exhibit A
1
1.
2
2.
3
3.
4.
5.
5 6.
7.
6 8.
9.
7 10.
4

8 11.
9 12.
10 13.
11 14.
15.
12 16.
13 17.
18.
14
19.
15
20.
16
21.
17
22.
18
23.
19 24.
25.
20
26.
21
27.
22
28.
23
29.
24
30.
25 31.
32.
26 33.
27 34.
35.
28

“Champagne Tango” Limited Edition, Michael Goddard, Giclee on canvas, signed by artist,
Numbered 207/250, 40" X 24" including frame,
Marc Chagall Etching "Soleil Aux Amoureux" black & white Limited Edition Etching, signed by
artists, Numbered 1 of 60, 12"x 9" including frame,
Joan Miro, The Perseides I, 1970, Registration No.147727.0018,
Joan Miro, The Perseides III, 1970, Registration No. 147727.0018,
Joan Miro, Oda A Joan Miro (C.905), 1973, Registration No. 177246.001,
Andras Markos, Abstract XV111, 2000, Registration No. 110777.0000,
Scott Jacobs, After the Ride, 2005, Registration No. 151835.0215,
Scott Jacobs, Summer Red, 2005, Registration No. 151836.0423,
Scott Jacobs, Roses or Red, 2005, Registration No. 151837.0193,
Diamond engagement ring, CTR RD, diamond 1.90 CTS., GIA Cert # 10074955, E Color, SI,
Plat. Mtg. with 6 top bags Wgt .65 CTS and 2 RD diamonds weighing .30 CTS,
Diamond necklace containing 7 diamonds Wgt. 1.10 CTS. G Color, VS2 set in handmade
white gold necklace,
668 Pair of diamond St. Earrings - 2 round diamonds weighing Approx. 1.50 CTS., G Color, SI1,
set in white gold mounting,
Diamond bracelet containing 60 RD diamonds, weighing 3.51 CTS., G Color, VS2, set in 18kt
gold channel mounting,
Cartier Roadster, stainless steel watch, S/N 699127D,
Steel and Gold Rolex with Roman Dial, Model #R0250005, S/N R79173373B6252K79897,
Cartier platinum and diamond Star of David Charm Approx. 1.20 CTS. Fiche #007262125, Ref.
#HY300021, S/N 869388,
14kt Gold and Onyx Bracelet with interconnecting Marquise stones,
Approximately $4,740.00 in the form of a Cashier’s Check in lieu of a Man's diamond ring
containing 3 full cut RD. diamonds .74 CTS., Color G, VS2, set in handmade platinum setting,
Diamond wedding ring containing 3 full cut RD diamonds .74 CTS, Color G, VS2, set in
handmade platinum setting,
Diamond Eternity Necklace containing 215 full cut round diamonds weight 2.34 CTS., diamonds
are G Color, VS2 set in white gold pave necklace mounting, 17",
Pair of diamond stud earrings containing 2 Princess cut diamonds, weighing 2.40 CTS., G-H
Color, VS2, set in white gold mappings,
Patek Philippe automatic annual calendar watch, black strap, 18kt, white gold case, grey dial,
Movement #3131717, Case #4096366,
Cartier Tank Francaise Ring Wg-1/2 diamond-Ref B4054750, S/N CR0138,
Men’s Rolex stainless steel and platinum yacht master watch,
Stainless steel Franck Muller Biretro chronograph watch with black alligator strap, Model
#7850CCBACB,
Jaeger Le-Coultre Men's Grand Reveil watch in platinum, leather strap, Limited Edition, Model
Q163644A-12,
Panerai Radiomir 45mm chronograph black stainless steel watch Serial #6715PB0569224
Reference #PAM00288,
Parmigiani Fleurier stainless steel and black leather chronograph watch, Reference
#PF003FLP1,
Vacheron Constantin Overseas stainless steel chronograph watch, Model #49150/B01A CAE
#1158537,
Blancpain stainless steel chrono perpetual calendar watch, Model #2685F1130FI Case #102,
IWC Big Pilot platinum watch, Model #500413, Serial #3406085,
IWC Mark XVI stainless steel watch, Model #325512, Serial #3355682,
Patek Philippe stainless steel watch with diamonds, Model #4910/10A-010, Serial
#3592550/4855430,
Patek Philippe platinum watch with diamond, Model #5135P-001, Serial #3920424/4455746,
Women’s Roberto Coin white gold and diamond bracelet,
3

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

36.
1 37.
38.
2

Women’s Roberto Coin white gold and diamond bracelet,
Roberto Coin Rose gold and diamond bracelet, and
Men's Panerai Limior power reserve watch, 2005 Regatta - 125 of 500.

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4

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