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

Filing 6

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 11/28/16 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 1/24/17.(Washington, S)

1
2
3
4
5

PHILLIP A. TALBERT
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

6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,

12
13
14
15
16
17
18
19
20
21
22
23

Plaintiff,
v.
APPROXIMATELY $177,820.00 IN U.S
CURRENCY,

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,
Defendants.

24
25

2:16-MC-00101-MCE-CKD

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:
27

1.

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

28 Service, seized the above-referenced defendant currency and defendant funds pursuant to Federal seizure
1
Stipulation and Order to Extend Time
29

1 warrants.
2

2.

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

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

3.

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

8 2016, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
10 forfeiture.
11

4.

By Stipulation and Order filed August 29, 2016, the parties stipulated to extend to

12 November 25, 2016, the time in which the United States is required to file a civil complaint for forfeiture
13 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
14 subject to forfeiture.
15

5.

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

16 January 24, 2017, the time in which the United States is required to file a civil complaint for forfeiture
17 against the defendant currency and defendant funds and/or to obtain an indictment alleging that the
18 defendant currency and defendant funds are subject to forfeiture.
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
29

2

Stipulation and Order to Extend Time

1

6.

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 January 24, 2017.
5
6
7 Dated: 11/22/2016

PHILLIP A. TALBERT
United States Attorney

8
9

By:

10

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

11
12 Dated: 11/22/2016
13

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

14

As authorized via email

15
16

IT IS SO ORDERED.

17 Dated: November 28, 2016
18
19
20
21
22
23
24
25
26
27
28
29

3

Stipulation and Order to Extend Time