United States of America v. Approximately $52,893.37 in U.S. Currency seized from Wells Fargo Account 1838449153

Filing 3

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/17/14: The deadline by which the United States shall file a complaint for forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture is extended to May 21, 2014.(Kaminski, H)

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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2:14-MC-00055-TLN-AC

v.

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STIPULATION AND ORDER
EXTENDING TIME FOR FILING
A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $52,893.37 IN U.S.
CURRENCY SEIZED FROM WELLS FARGO
BANK ACCOUNT 1838449153, HELD IN THE
NAME OF DAVID ZINNEL,

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Defendant
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It is hereby stipulated by and between the United States of America and claimant David Zinnel
(“claimant”), by and through their respective counsel, as follows:
1.

On or about January 21, 2014, claimant David Zinnel filed a claim, in the administrative

forfeiture proceedings, with the Internal Revenue Service with respect to the Approximately
$52,893.37 in U.S. Currency seized from Wells Fargo Bank account 1838449153, held in the name of
David Zinnel (hereafter “defendant funds”), which were seized on November 5, 2013.
2.

The Internal Revenue Service has sent the written notice of intent to forfeit required by

18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
claim to the defendant funds under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant
has filed a claim to the defendant funds as required by law in the administrative forfeiture proceeding.
3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for
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Stipulation to Extend Time to File Complaint

1 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
2 funds are subject to forfeiture within ninety days after a claim has been filed in the administrative
3 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
4 the parties. That deadline is April 21, 2014.
4.

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

6 to May 21, 2014, the time in which the United States is required to file a civil complaint for forfeiture
7 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
8 to forfeiture.
5.

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

10 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
11 alleging that the defendant funds are subject to forfeiture shall be extended to May 21, 2014.
12 Dated:

4/15/14

BENJAMIN B. WAGNER
United States Attorney

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

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Dated:

4/15/14

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/s/ Patrick K. Hanly
PATRICK K. HANLY
Attorney for Claimant David Zinnel
Authorized via email

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IT IS SO ORDERED.

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Dated: April 17, 2014

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint