United States of America v. Approximately $142,020.00 in U.S. Currency

Filing 2

STIPULATION and ORDER extending time to file complaint for forfeiture signed by Senior Judge William B. Shubb on 2/11/14. (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,

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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

19 Mancia (“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
23 or 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

e
g.
1 forfeiture proceeding
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3.

Under 18 U.S.C. § 983(a)(3)(A the Unit States is required to f a compla for
r
A),
ted
file
aint

e
c
d/or
n
ment
fendant
3 forfeiture against the defendant currency and to obtain an indictm alleging that the defe
o
w
y
been filed in the adminis
n
strative
4 currency is subject to forfeiture within ninety days after a claim has b
e
g,
ds
ine
d
wn
eement of the
e
5 forfeiture proceeding unless the court extend the deadli for good cause show or by agre
T
ne
ry
6 parties. That deadlin is Februar 17, 2014.
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4.

As pro
ovided in 18 U.S.C. § 98
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83(a)(3)(A), the parties w by agre
wish
eement to ex
xtend to

2
me
S
uired to file a civil comp
plaint for forfeiture
8 April 3, 2014, the tim in which the United States is requ
he
t
nd/or to obta an indictm allegin that the de
ain
ment
ng
efendant cur
rrency is
9 against th defendant currency an
o
10 subject to forfeiture.
0
11
1

5.

Accor
rdingly, the parties agree that the dea
p
e
adline by wh the Unit States sh be
hich
ted
hall

mplaint for fo
orfeiture aga
ainst the defe
endant curre
ency and/or t obtain an indictment
to
12 required to file a com
2
t
endant curren is subjec to forfeitu shall be e
ncy
ct
ure
extended to A
April 3, 2014
4.
13 alleging that the defe
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14 Dated: 2/11/14
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2

BEN
NJAMIN B. WAGNER
Unit States At
ted
ttorney

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By:
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/s/ K
Kevin C. Kha
asigian
KEV C. KHA
VIN
ASIGIAN
Assi
istant U.S. A
Attorney

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20 Dated: 2/10/14
0
2
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/s/ S
Stuart Goldfa
arb
STU
UART GOLD
DFARB
Atto
orney for cla
aimant Newt Mancia
ton

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(Aut
thorized by email)

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IT IS SO OR
T
RDERED.
Dated: February 11, 2014
F

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S
Stipulation and Order to E
Extend Time
e