United States of America v. Approximately $6,350.00 in U.S. Currency

Filing 2

STIPULATION AND ORDER signed by District Judge Troy L. Nunley on 1/26/2016 ORDERING the United States of America 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 by 4/25/2016. (Michel, G.)

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BENJAMIN B. WAGNER
United States Attorney
KEVIN C. KHASIGIAN
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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2:16-MC-00010-TLN-AC

Plaintiff,
v.
APPROXIMATELY $6,350.00 IN U.S.
CURRENCY,

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

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Defendant.
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It is hereby stipulated by and between the United States of America and potential claimant

19 Gregory Warren (“claimant”), appearing in propria persona, as follows:
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1.

On or about October 28, 2015, claimant filed a claim in the administrative forfeiture

21 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $6,350.00 in U.S.
22 Currency (hereafter “defendant currency”), which was seized on or about September 19, 2015.
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2.

The U.S. Postal Inspection Service has sent the written notice of intent to forfeit required

24 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
25 claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimant
26 has filed a claim to the defendant currency as required by law in the 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
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1 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
2 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
3 parties. That deadline is January 26, 2016.
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4.

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

5 25, 2016, the time in which the United States is required to file a civil complaint for forfeiture against the
6 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
7 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 April 25, 2016.
11 Dated: 1/25/16

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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16 Dated: 1/25/16
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/s/ Gregory Warren
GREGORY WARREN
Claimant, appearing in propria persona

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(Authorized by phone)

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IT IS SO ORDERED.

22 Dated: January 26, 2016
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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time