United States of America v. Approximately $30,000.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 12/23/2014 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 shall be EXTENDED to 2/24/2015. (Zignago, K.)

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-00152-TLN-CKD

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 $30,000.00 IN U.S.
CURRENCY,

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Defendant
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It is hereby stipulated by and between the United States of America and claimant Juber Flores-

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

On or about September 25, 2014, claimant Juber Flores-Suarez filed a claim, in the

20 administrative forfeiture proceedings, with the Drug Enforcement Administration with respect to the
21 Approximately $30,000.00 in U.S. Currency (hereafter “defendant currency”), which was seized on
22 June 9, 2014.
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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
26 other than the claimant has filed a claim to the defendant currency as required by law in the
27 administrative 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
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Stipulation to Extend Time to File Complaint

1 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
2 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
3 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
4 the parties. That deadline is December 26, 2014.
4.

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

6 February 24, 2015, the time in which the United States is required to file a civil complaint for forfeiture
7 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
8 subject to forfeiture.
5.

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

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

12/12/14

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:

12/12/14

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/s/ Brett A. Purtzer
BRET A. PURTZER
Attorney for Claimant Juber Flores-Suarez
Authorized via phone

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IT IS SO ORDERED.

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Dated: December 23, 2014

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint