United States of America v. Approximately $177,820.00 in U.S. Currency et al

Filing 4

STIPULATION AND ORDER signed by District Judge Morrison C. England, Jr., on 8/26/16 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 is EXTENDED to 11/25/2016. (Kastilahn, A)

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PHILLIP A. TALBERT
Acting United States Attorney
NIRAV K. DESAI
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]
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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v.
APPROXIMATELY $177,820.00 IN U.S
CURRENCY,

2:16-MC-00101-MCE-CKD
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $130,000.00 IN U.S
CURRENCY,
APPROXIMATELY $50,000.00 IN THE
FORM OF A CASHIER’S CHECK,
APPROXIMATELY $8,323.00 IN THE
FORM OF A CASHIER’S CHECK,
APPROXIMATELY $4,550.00 IN THE
FORM OF A CASHIER’S CHECK,
and
APPROXIMATELY $4,796.00 IN THE
FORM OF A CASHIER’S CHECK,

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

26 Prasad (“claimant”), by and through his respective counsel, as follows:
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Stipulation and Order to Extend Time

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1.

On or about March 29, 2016, the United States State Department, Diplomatic Security

2 Service, seized the above-referenced defendant currency and defendant funds pursuant to Federal seizure
3 warrants.
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2.

Under 18 U.S.C. §§ 983(a)(1)(A)(i)-(iii), and 983(a)(3)(A), the United States is required to

5 send notice to potential claimants, file a complaint for forfeiture against the defendant currency and
6 defendant funds, or obtain an indictment alleging that the defendant currency and defendant funds are
7 subject to forfeiture within sixty days of seizure, unless the court extends the deadline for good cause
8 shown or by agreement of the parties. That deadline is May 28, 2016.
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3.

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

10 August 26, 2016, the time in which the United States is required to file a civil complaint for forfeiture
11 against the defendant currency and defendant funds and/or to obtain an indictment alleging that the
12 defendant currency and defendant funds are subject to forfeiture.
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4.

By Stipulation and Order filed June 2, 2016, the parties stipulated to extend to August 26,

14 2016, the time in which the United States is required to file a civil complaint for forfeiture against the
15 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
16 forfeiture.
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Stipulation and Order to Extend Time

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5.

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

2 required to file a complaint for forfeiture against the defendant currency and defendant funds and/or to
3 obtain an indictment alleging that the defendant currency and defendant funds are subject to forfeiture
4 shall be extended to November 25, 2016.
5 Dated:

8/24/2016

PHILLIP A. TALBERT
Acting 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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10 Dated:

8/24/2016

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/s/ Scott L. Tedmon
SCOTT L. TEDMON
Attorney for Potential Claimant Abhijit Prasad

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(As authorized via email)

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IT IS SO ORDERED.

15 Dated: August 26, 2016
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Stipulation and Order to Extend Time