USA v. Approximately $5,000.00 in U.S. Currency, et al
Filing
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STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 1/23/14 ORDERING the parties agree that the deadline by which 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 4/16/14. (Becknal, R)
1 BENJAMIN B. WAGNER
United States Attorney
2 JEFFREY A. SPIVAK
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: (916) 554-2700
5 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.
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2:14-MC-00008-LKK-KJN
STIPULATION AND ORDER
EXTENDING TIME FOR FILING
A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN
INDICTMENT ALLEGING
FORFEITURE
APPROXIMATELY $5,000.00 IN U.S.
CURRENCY, and
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APPROXIMATELY $1,216.00 IN U.S.
CURRENCY,
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Defendants
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It is hereby stipulated by and between the United States of America and claimants
20 Lee Vang and Chai Chang (“claimants”), in Pro Se, as follows:
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1.
On or about October 18, 2013, claimants Lee Vang and Chai Chang filed
22 claims, in the administrative forfeiture proceedings, with the Internal Revenue Service
23 with respect to the Approximately $5,000.00 in U.S. Currency and Approximately
24 $1,216.00 in U.S. Currency (hereafter “defendant currency”), which was seized on August
25 28, 2013.
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2.
The Internal Revenue Service has sent the written notice of intent to forfeit
27 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has
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Stipulation to Extend Time to File Complaint
1 expired for any person to file a claim to the defendant currency under 18 U.S.C. §
2 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the defendant
3 currency as required by law in the administrative forfeiture proceeding.
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3.
Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a
5 complaint for forfeiture against the defendant currency and/or to obtain an indictment
6 alleging that the defendant currency is subject to forfeiture within ninety days after a
7 claim has been filed in the administrative forfeiture proceedings, unless the court extends
8 the deadline for good cause shown or by agreement of the parties. That deadline is
9 January 16, 2014.
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4.
As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement for an
11 extension to April 16, 2014, the time in which the United States is required to file a civil
12 complaint for forfeiture against the defendant currency and/or to obtain an indictment
13 alleging that the defendant currency is subject to forfeiture.
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Stipulation to Extend Time to File Complaint
5.
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Accordingly, the parties agree that the deadline by which the United States
2 shall be required to file a complaint for forfeiture against the defendant currency and/or
3 to obtain an indictment alleging that the defendant currency is subject to forfeiture shall
4 be extended to April 16, 2014.
5 Dated:
1/14/14
BENJAMIN B. WAGNER
United States Attorney
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/s/ Jeffrey A. Spivak
JEFFREY A. SPIVAK
Assistant U.S. Attorney
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Dated:
1/16/14
/s/ Lee Vang
LEE VANG
Claimant, in PRO SE
12 Dated:
1/16/14
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/s/ Chai Chang
CHAI CHANG
Claimant, in PRO SE
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(Signatures retained by attorney)
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16 IT IS SO ORDERED.
17 Dated: January 23, 2014.
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Stipulation to Extend Time to File Complaint
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