United States of America v. Approximately $15,000.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/17/16 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 shall be extended to January 17, 2017. (Becknal, R)

1

4

PHILLIP A. TALBERT
Acting United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

5

Attorneys for the United States

2
3

6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,

12

Plaintiff,

13

v.

2:16-MC-00167-TLN-KJN

14

APPROXIMATELY $15,000.00 IN U.S.
CURRENCY,

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 Renita Credle

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

1.

On or about July 18, 2016, claimant Credle filed a claim in the administrative forfeiture

20 proceedings with the United States Postal Inspection Service with respect to the Approximately
21 $15,000.00 in U.S. Currency. (hereafter “defendant currency”), which was seized on May 7, 2016.
22

2.

The United States Postal Inspection Service 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 claimant has 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 and Order to Extend Time to File
29
Complaint

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 October 18, 2016.
4

4.

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

5 January 17, 2017, 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.
8

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 January 17, 2017.
11 Dated:

10/14/2016

PHILLIP A. TALBERT
Acting United States Attorney

12
13

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

14
15
16 Dated:

10/14/2016

17

/s/ Renita Credle
RENITA CREDLE
Claimant, In Propria Persona

18
19

IT IS SO ORDERED.

20 Dated: October 17, 2016
21
22
23

Troy L. Nunley
United States District Judge

24
25
26
27
28
29
30

2

Stipulation and Order to Extend Time to File
Complaint