United States of America v. Approximately $142,020.00 in U.S. Currency
Filing
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STIPULATION and ORDER signed by Senior Judge William B. Shubb on 7/30/14 ORDERING 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 8/29/2014. (Kastilahn, A)
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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: (916) 554-2700
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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 $142,020.00 IN
U.S. CURRENCY,
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2:14-MC-00025-WBS-DAD
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 claimant Newton Mancia
19 (“claimant”), by and through their respective counsel, as follows:
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1.
On or about November 19, 2013, claimant Newton Mancia filed a claim in the
21 administrative forfeiture proceeding with the Drug Enforcement Administration with respect to the
22 Approximately $142,020.00 in U.S. Currency (hereafter “defendant currency”), which was seized on or
23 about October 12, 2012.
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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
Stipulation and Order to Extend Time
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 was February 17, 2014.
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4.
By Stipulation and Order filed February 12, 2014, the parties stipulated to extend to April
8 3, 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
10 forfeiture.
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5.
By Stipulation and Order filed April 2, 2014, the parties stipulated to extend to May 5,
12 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
13 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
14 forfeiture.
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6.
By Stipulation and Order filed May 2, 2014, the parties stipulated to extend to May 30,
16 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
17 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
18 forfeiture.
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7.
By Stipulation and Order filed May 30, 2014, the parties stipulated to extend to June 30,
20 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
21 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
22 forfeiture.
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8.
By Stipulation and Order filed June 30, 2014, the parties stipulated to extend to July 30,
24 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
25 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
26 forfeiture.
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9.
As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend
28 to August 29, 2014, the time in which the United States is required to file a civil complaint for forfeiture
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Stipulation and Order to Extend Time
1 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
2 subject to forfeiture.
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10.
Accordingly, the parties agree that the deadline by which the United States shall be
4 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
5 alleging that the defendant currency is subject to forfeiture shall be extended to August 29, 2014.
6 Dated: 7/29/14
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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10 Dated: 7/28/14
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/s/ Stuart Goldfarb
STUART GOLDFARB
Attorney for claimant Newton Mancia
(Authorized by email)
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IT IS SO ORDERED.
14 Dated: July 30, 2014
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Stipulation and Order to Extend Time
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