United States of America v. Approximately $4,100.00 in U.S. Currency

Filing 8

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/24/2014 ORDERING the deadline for the United States to file a complaint for forfeiture is EXTENDED to 1/20/2015. (Donati, J)

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BENJAMIN B. WAGNER
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

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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 $4,100.00 IN U.S.
CURRENCY,

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2:14-MC-00071-WBS-KJN
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

Defendant.

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

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

On or about February 4, 2014, claimant filed a claim in the administrative forfeiture

21 proceeding with the Drug Enforcement Administration with respect to the Approximately $4,100.00 in
22 U.S. Currency (hereafter “defendant currency”), which was seized on or about October 10, 2013.
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2.

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

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

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3.

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

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

By Stipulation and Order filed May 7, 2014, the parties stipulated to extend to July 7,

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

By Stipulation and Order filed July 7, 2014, the parties stipulated to extend to October 6,

11 2014, the time in which the United States is required to file a civil complaint for forfeiture against the
12 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
13 forfeiture.
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6.

By Stipulation and Order filed September 30, 2014, the parties stipulated to extend to

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

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

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

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

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Stipulation and Order to Extend Time

1 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
2 alleging that the defendant currency is subject to forfeiture shall be extended to January 20, 2015.
3 Dated: 11/21/14

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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8 Dated: 11/21/14
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/s/ Kelly Babineau
KELLY BABINEAU
Attorney for claimant Rachel Marie Regan
(Authorized by email)

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IT IS SO ORDERED.

12 Dated: November 24, 2014
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Stipulation and Order to Extend Time