United States of America v. Approximately $14,600.00 in U.S. Currency et al

Filing 11

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/11/2015 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 is EXTENDED to 6/5/2015. (Zignago, K.)

1 BENJAMIN B. WAGNER
United States Attorney
2 KEVIN C. KHASIGIAN
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
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,
v.
APPROXIMATELY $14,600.00 IN U.S.
CURRENCY, and

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2:14-MC-00048-TLN-AC
STIPULATION AND ORDER
EXTENDING TIME FOR FILING A
COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN
INDICTMENT ALLEGING
FORFEITURE

APPROXIMATELY $5,900.00 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 claimant Felipe S.

20 Gonzalez (“claimant”), by and through their respective counsel, as follows:
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1.

On or about January 9, 2014, claimant Felipe S. Gonzalez filed a claim, in the

22 administrative forfeiture proceedings, with the Drug Enforcement Administration with respect to the
23 Approximately $14,600.00 in U.S. Currency and Approximately $5,900.00 in U.S. Currency
24 (collectively “defendant currency”), which was seized on August 7, 2013.
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2.

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

26 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
27 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person
28 other than the claimant has filed a claim to the defendant currency as required by law in the
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Stipulation and Order to Extend Time
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1 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 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 proceedings, unless the court extends the deadline for good cause shown or by agreement
6 of the parties. The deadline was April 9, 2014.
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4.

By Stipulation and Order filed April 9, 2014, the parties stipulated to extend to July 8,

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

By Stipulation and Order filed July 3, 2014, the parties stipulated to extend to

12 October 6, 2014, the time in which the United States is required to file a civil complaint for
13 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
14 currency is subject to forfeiture.
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6.

By Stipulation and Order filed October 3, 2014, the parties stipulated to extend to

16 December 5, 2014, the time in which the United States is required to file a civil complaint for
17 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
18 currency is subject to forfeiture.
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7.

By Stipulation and Order filed December 3, 2014, the parties stipulated to extend to

20 March 5, 2015, the time in which the United States is required to file a civil complaint for forfeiture
21 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
22 subject to forfeiture.
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8.

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

24 extension to June 5, 2015, the time in which the United States is required to file a civil complaint for
25 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
26 currency is subject to forfeiture.
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Stipulation and Order to Extend Time

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9.

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

2 required to file a complaint for forfeiture against the defendant currency and/or to obtain an
3 indictment alleging that the defendant currency is subject to forfeiture shall be extended to June 5,
4 2015.
5 Dated:

3/3/2015

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:

3/2/2015

/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for claimant
Felipe S. Gonzalez
(Authorized via email)

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IT IS SO ORDERED.

15 Dated: March 11, 2015
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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time