USA v. Approx. $289,695.00 in U.S. Currency et al

Filing 4

STIPULATION and ORDER 3 for extension of time signed by Senior Judge William B. Shubb on 5/27/2014. Parties agree that the deadline for United States shall file a Complaint of Forfeiture and/or obtain an Indictment alleging defendant assets shall be EXTENDED to 8/21/2014. (Marciel, M)

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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2:14-MC-00065-WBS-KJN

Plaintiff,
v.

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

APPROXIMATELY $289,695.00 IN U.S.
CURRENCY,

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APPROXIMATELY $20,389.00 IN U.S.
CURRENCY,
APPROXIMATELY $5,439.00 IN U.S.
CURRENCY,

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APPROXIMATELY $7,438.56 SEIZED FROM
TRAVIS CREDIT UNION ACCOUNT
NUMBER 432952,

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APPROXIMATELY $4,536.29 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
8813392803,

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APPROXIMATELY $1,889.79 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
2297760957,

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APPROXIMATELY $1,265.76 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
2783081207,

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APPROXIMATELY $1,002.30 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
7218921497,

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1

Stipulation and Order to Extend Time
for Filing A Complaint for Forfeiture

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APPROXIMATELY $800.65 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
3827072285,
APPROXIMATELY $134.22 SEIZED FROM
WELLS FARGO BANK ACCOUNT NUMBER
1940941055,
APPROXIMATELY $3,576.83 SEIZED FROM
UNION BANK ACCOUNT NUMBER
11712478,
APPROXIMATELY $1,524.97 SEIZED FROM
UNION BANK ACCOUNT NUMBER
11712486,
APPROXIMATELY $2,002.79 SEIZED FROM
BANK OF AMERICA ACCOUNT NUMBER
19776-06262,
APPROXIMATELY $868.47 SEIZED FROM
BANK OF AMERICA ACCOUNT NUMBER
19776-05854,
APPLE MAC DESKTOP COMPUTER, SERIAL
NUMBER CD2K2BM9DNCV, and

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2001 CROWNLINE 212 DB POWER BOAT
WITH TRAILER, VIN: JTC42712A101,
CALIFORNIA LICENSE NUMBER:4AC1996,

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Defendants.

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

20 Robinson and Kimberly Santiago-Robinson, through undersigned counsel, as follows:
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1.

On or about February 10, 2014, claimants Brian Corry Robinson and Kimberly

22 Santiago-Robinson filed a claim, in the administrative forfeiture proceedings, with the Drug
23 Enforcement Administration with respect to the assets captioned above (hereafter “defendant assets”),
24 which were seized between October 24, 2013 and October 31, 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 assets under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other
28 than the claimant has filed a claim to the defendant assets as required by law in the administrative
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2

Stipulation and Order to Extend Time
for Filing A Complaint for Forfeiture

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 assets and/or to obtain an indictment alleging that the defendant assets
4 are subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
5 proceedings, unless the court extends the deadline for good cause shown or by agreement of the parties.
6 That deadline is May 9, 2014.
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4.

By Stipulation and Order filed May 1, 2014, the parties stipulated to extend to June 30,

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

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

12 to August 21, 2014, the time in which the United States is required to file a civil complaint for
13 forfeiture against the defendant assets and/or to obtain an indictment alleging that the defendant assets
14 are subject to forfeiture.
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6.

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 assets and/or to obtain an indictment
17 alleging that the defendant assets are subject to forfeiture shall be extended to August 21, 2014.
18 Dated: 5/22/14

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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22 Dated: 5/22/14
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/s/ David M. Michael
DAVID M. MICHAEL
Attorney for Claimants

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(Authorized via email 5/22/14)
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26 IT IS SO ORDERED.
27 Dated: May 27, 2014
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3

Stipulation and Order to Extend Time
for Filing A Complaint for Forfeiture