United States of America v. Approximately $65,534.85 in U.S. Currency seized from First Bank Account 242-5126004, et al

Filing 2

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/17/14. The United States shall file a complaint for forfeiture and/or obtain an indictment by 5/30/14. (Manzer, C)

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-00056-TLN-EFB

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 $65,534.85 IN U.S.
CURRENCY SEIZED FROM FIRST BANK
ACCOUNT 242-5126004, HELD IN THE NAME
OF STEVEN ZINNEL, and

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APPROXIMATELY $53,362.51 IN U.S.
CURRENCY SEIZED FROM WELLS FARGO
BANK ACCOUNT 3584700995, HELD IN THE
NAME OF STEVEN ZINNEL dba BEST BUILD,

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Defendants.
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It is hereby stipulated by and between the United States of America and claimant Steven Zinnel

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

On or about January 30, 2014, claimant Steven Zinnel filed a claim, in the

24 administrative forfeiture proceedings, with the Internal Revenue Service with respect to the
25 Approximately $65,534.85 in U.S. Currency seized from First Bank account 242-5126004, held in the
26 name of Steven Zinnel and Approximately $53,362.51 in U.S. Currency seized from Wells Fargo Bank
27 account 358700995, held in the name of Steven Zinnel dba Best Build (hereafter “defendant funds”),
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1

Stipulation to Extend Time to File Complaint

1 which were seized on November 5, 2013.
2.

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

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

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

7 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
8 funds are subject to forfeiture within ninety days after a claim has been filed in the administrative
9 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
10 the parties. That deadline is April 30, 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

12 to May 30, 2014, the time in which the United States is required to file a civil complaint for forfeiture
13 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
14 to forfeiture.
5.

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

16 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
17 alleging that the defendant funds are subject to forfeiture shall be extended to May 30, 2014.
18 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/ Suzanne A. Luban
SUZANNE A. LUBAN
Attorney for Claimant Steven 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
Stipulation to Extend Time to File Complaint