United States of America v. Approximately $19,970.00 in U.S. Currency

Filing 16

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 6/30/15 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 is EXTENDED to 8/31/15. (Becknal, R)

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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,
v.

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APPROXIMATELY $19,970.00 IN
U.S. CURRENCY,

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

Defendant.

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2:14-MC-00075-MCE-KJN

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

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

On or about February 7, 2014, claimant Vanessa West filed a claim in the administrative

20 forfeiture proceeding with the Drug Enforcement Administration with respect to the Approximately
21 $19,970.00 in U.S. Currency (hereafter “defendant currency”), which was seized on or about
22 December 18, 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 8, 2014.
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4.

By Stipulation and Order filed May 7, 2014, the parties stipulated to extend to August 6,

7 2014, the time in which the United States is required to file a civil complaint of 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 August 11, 2014, the parties stipulated to extend to

11 October 3, 2014, the time in which the United States is required to file a civil complaint of forfeiture
12 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
13 subject to forfeiture.
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6.

By Stipulation and Order filed October 2, 2014, the parties stipulated to extend to

15 December 2, 2014, the time in which the United States is required to file a civil complaint of 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.

By Stipulation and Order filed December 2, 2014, the parties stipulated to extend to

19 January 30, 2015, the time in which the United States is required to file a civil complaint of 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.

By Stipulation and Order filed January 27, 2015, the parties stipulated to extend to March

23 2, 2015, the time in which the United States is required to file a civil complaint of forfeiture against the
24 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
25 forfeiture.
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9.

By Stipulation and Order filed March 4, 2015, the parties stipulated to extend to May 1,

27 2015, the time in which the United States is required to file a civil complaint of forfeiture against the
28 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
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Stipulation and Order to Extend Time
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1 forfeiture.
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10.

By Stipulation and Order filed May 11, 2015, the parties stipulated to extend to June 30,

3 2015, the time in which the United States is required to file a civil complaint of forfeiture against the
4 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
5 forfeiture.
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11.

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

7 to August 31, 2015, the time in which the United States is required to file a civil complaint for forfeiture
8 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
9 subject to forfeiture.
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12.

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

11 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
12 alleging that the defendant currency is subject to forfeiture shall be extended to August 31, 2015.
13 Dated: 6/24/15

BENJAMIN B. WAGNER
United States Attorney

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By:

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Dated: 6/23/15

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/s/ Justin T. Mixon
JUSTIN T. MIXON
Attorney for claimant Vanessa West
(Authorized by telephone)

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

IT IS SO ORDERED.

23 Dated: June 30, 2015
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Stipulation and Order to Extend Time