United States of America v. Approximately $19,880.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 5/12/15 ORDERING the parties agree 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 August 4, 2015. (Becknal, R)

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BENJAMIN B. WAGNER
United States Attorney
MARILEE L. MILLER
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.

2:15-MC-00047-WBS-KJN
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

APPROXIMATELY $19,880.00 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 Tristram Gray

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

On or about March 9, 2015, claimant filed a claim in the administrative forfeiture

21 proceeding with the Drug Enforcement Administration with respect to the Approximately $19,880.00 in
22 U.S. Currency (hereafter “defendant currency”), which was seized on or about December 17, 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 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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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 and Order to Extend Time

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 proceeding, unless the court extends the deadline for good cause shown or by agreement of the
4 parties. That deadline is June 5, 2015.
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4.

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

6 August 4, 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.
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5.

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 August 4, 2015.
12 Dated: 5/12/15

BENJAMIN B. WAGNER
United States Attorney

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By:
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/s/ Marilee L. Miller
MARILEE L. MILLER
Assistant U.S. Attorney

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/s/ David J. Cohen
DAVID J. COHEN, ESQ.
Attorney for claimant Tristram G. Jensvold

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(original signature retained by attorney)

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IT IS SO ORDERED.
Dated: May 12, 2015

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Stipulation and Order to Extend Time