United States of America v. Approximately $21,310.00 in U.S. Currency

Filing 2

ORDER signed by District Judge Troy L. Nunley on 6/25/2015 ORDERING 1 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 7/27/2015. (Reader, L)

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
6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,

12

Plaintiff,

13

v.

14

APPROXIMATELY $21,310.00 IN U.S.
CURRENCY,

2:15-MC-00071-TLN-AC
STIPULATION AND ORDER
EXTENDING TIME FOR FILING
A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

15
Defendant.
16
17

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

18 Macedo (“claimant” or “Macedo”) by and through their respective counsel, as follows:
19

1.

On or about March 30, 2015, claimant Macedo filed a claim in the administrative

20 forfeiture proceedings with the Drug Enforcement Administration with respect to the Approximately
21 $21,310.00 in U.S. Currency, which was seized on January 28, 2015.
22

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 claimants have filed a claim to the defendant currency as required by law in the
26 administrative forfeiture proceeding.
27

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
1
Stipulation to Extend Time to File Complaint
29
30

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 June 26, 2015.
4.

4

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

5 July 27, 2015, the time in which the United States is required to file a civil complaint for forfeiture
6 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
7 subject to forfeiture.
5.

8

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 July 27, 2015.
11 Dated:

6/22/15

BENJAMIN B. WAGNER
United States Attorney

12
/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

13
14
15

Dated:

6/18/15

17

/s/ Jacek W. Lentz
JACEK W. LENTZ
Attorney for Claimant
Ricardo Curiel Macedo

18

(authorized via email)

16

19
20 IT IS SO ORDERED
21 Dated: June 25, 2015
22
23
24

Troy L. Nunley
United States District Judge

25
26
27
28
29
30

2

Stipulation to Extend Time to File Complaint