United States of America v. Approximately $104,340.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 1/22/2014 ORDERING 1 that 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 4/17/2014. (Reader, 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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Plaintiff,

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v.
APPROXIMATELY $104,340.00 IN
U.S. CURRENCY,

2:14-MC-00007-MCE-EFB
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 potential claimant Brian

19 Keith Hall (“claimant”), by and through their respective counsel, as follows:
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1.

On or about October 21, 2013, claimant Brian Keith Hall filed a claim in the

21 administrative forfeiture proceeding with the Drug Enforcement Administration with respect to the
22 Approximately $104,340.00 in U.S. Currency (hereafter “defendant currency”), which was seized on
23 or about July 22, 2013.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

25 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
26 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other
27 than claimant has filed a claim to the defendant currency as required by law in the administrative
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1 forfeiture proceeding.
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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for

3 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
4 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
5 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
6 parties. That deadline is January 17, 2014.
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4.

As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to

8 April 17, 2014, the time in which the United States is required to file a civil complaint for forfeiture
9 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
10 subject to forfeiture.
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5.

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

12 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
13 alleging that the defendant currency is subject to forfeiture shall be extended to April 17, 2014.
14 Dated: 1/14/14

BENJAMIN B. WAGNER
United States Attorney

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By:

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

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20 Dated: 1/14/14
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/s/ Angie Palmerin
ANGIE PALMERIN
Attorney for claimant Brian Keith Hall

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(Authorized by phone)

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IT IS SO ORDERED.

24 Dated: January 22, 2014
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