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

Filing 4

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 7/3/14 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 10/6/2014. (Becknal, R)

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,

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v.
APPROXIMATELY $14,600.00 IN U.S.
CURRENCY, and

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APPROXIMATELY $5,900.00 IN U.S.
CURRENCY,

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

Defendants.

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It is hereby stipulated by and between the United States of America and

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

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

23 the administrative forfeiture proceedings, with the Drug Enforcement Administration
24 with respect to the Approximately $14,600.00 in U.S. Currency and Approximately
25 $5,900.00 in U.S. Currency (collectively “defendant currency”), which was seized on
26 August 7, 2013.
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2.

The Drug Enforcement Administration has sent the written notice of

28 intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties.
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Stipulation and Order to Extend Time

1 The time has expired for any person to file a claim to the defendant currency under 18
2 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the
3 defendant 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
8 extends the deadline for good cause shown or by agreement of the parties. The
9 deadline was April 9, 2014.
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4.

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

11 extend to July 8, 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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5.

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

15 an extension to October 6, 2014, the time in which the United States is required to file
16 a civil complaint for forfeiture against the defendant currency and/or to obtain an
17 indictment alleging that the defendant currency is subject to forfeiture.
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Stipulation and Order to Extend Time

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6.

Accordingly, the parties agree that the deadline by which the United

2 States shall be required to file a complaint for forfeiture against the defendant
3 currency and/or to obtain an indictment alleging that the defendant currency is subject
4 to forfeiture shall be extended to October 6, 2014.
5 Dated:

7/2/2014

BENJAMIN B. WAGNER
United States Attorney

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By:

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Dated:

7/2/2014

/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for claimant
Felipe S. Gonzalez

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(As authorized via phone)

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IT IS SO ORDERED.

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Dated: July 3, 2014.

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Stipulation and Order to Extend Time