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

Filing 6

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 5/2/14 ORDERING 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 5/30/2014. (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: [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 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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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.

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

16 to May 30, 2014, the time in which the United States is required to file a civil complaint for forfeiture
17 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
18 subject to forfeiture.
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7.

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

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Stipulation and Order to Extend Time

1 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
2 alleging that the defendant currency is subject to forfeiture shall be extended to May 30, 2014.
3 Dated: 5/1/14

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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7 Dated: 5/1/14
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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.

11 Dated: May 2, 2014
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Stipulation and Order to Extend Time