United States of America v. Approximately $27,676.66

Filing 2

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 11/20/2014 ORDERING the deadline for the United States to file a complaint for forfeiture and/or obtain an indictment is EXTENDED to 2/20/2015. (Donati, J)

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,
Plaintiff,

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2:14-MC-00126-MCE-DAD

v.
APPROXIMATELY $27,676.66 SEIZED
FROM US BANK ACCOUNT NUMBER 1
534 0187 5072, HELD IN THE NAMES OF
DONALD COAN, AND SCARLET HUGHES
POA,
Defendant.

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

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

20 potential claimant Larry Hughes, by and through their respective attorneys, as follows:
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1. On or about September 25, 2014, the Federal Bureau of Investigation (“FBI”)

22 seized the above-referenced defendant currency for federal forfeiture.
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2. Under 18 U.S.C. §§ 983(a)(1)(A)(i) and 983(a)(3)(A), the United States is

24 required to send notice to potential claimants, file a complaint for forfeiture against the
25 defendant currency, or obtain an indictment alleging that the defendant currency is
26 subject to forfeiture within sixty (“60”) days of seizure, unless the court extends the
27 deadline for good cause shown or by agreement of the parties. That deadline is
28 currently November 24, 2014.
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Stipulation and Order to Extend Time

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

2 extend to February 20, 2015, the time in which the United States is required to file a
3 civil complaint for forfeiture against the defendant properties and/or to obtain an
4 indictment alleging that the defendant properties are subject to forfeiture.
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4. Accordingly, the parties agree that the deadline by which the United States

6 shall be required to file a complaint for forfeiture against the defendant properties
7 and/or to obtain an indictment alleging that the defendant properties are subject to
8 forfeiture shall be extended to February 20, 2015.
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Dated: 10/28/14

BENJAMIN B. WAGNER
United States Attorney

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By:

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

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Dated: 10/28/14

/s/ Peter Boldin
PETER BOLDIN
Attorney for potential claimant
Larry Hughes
(Authorized by email)

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IT IS SO ORDERED.
Dated: November 20, 2014

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Stipulation and Order to Extend Time