United States of America v. Approximately $19,575.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/12/15: 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 February 12, 2015. (Kaminski, H)

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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2:15-MC-00004-WBS-AC

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

v.
APPROXIMATELY $19,575.00 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 Daniel Hagel,

18 through undersigned counsel, as follows:
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1.

On or about October 14, 2014, claimant Daniel Hagel filed a claim, in the administrative

20 forfeiture proceedings, with the Drug Enforcement Administration with respect to the defendant
21 currency captioned above (hereafter “defendant currency”), which was seized on July 30, 2014.
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2.

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

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

28 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
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Stipulation and Order to Extend Time
for Filing A Complaint for Forfeiture

1 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
2 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
3 the parties. That deadline is January 12, 2015.
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4.

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

5 to February 12, 2015, the time in which the United States is required to file a civil complaint for
6 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
7 currency is subject to forfeiture.
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5.

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

9 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
10 alleging that the defendant currency is subject to forfeiture shall be extended to February 12, 2015.
11 Dated: 1/9/2015

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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15 Dated: 1/9/2015
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/s/ Alan G. Karow
ALAN G. KAROW
Attorney for Claimant Daniel Hagel
(Authorized via email 1/9/15)

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19 IT IS SO ORDERED.
20 Dated: January 12, 2015
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Stipulation and Order to Extend Time
for Filing A Complaint for Forfeiture