United States of America v. Approximately $7,000.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 1/5/2017 ORDERING the time in which the United States is required to file a civil 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 1/20/2017.(Washington, S)

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PHILLIP A. TALBERT
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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Plaintiff,

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v.

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APPROXIMATELY $7,000.00 IN U.S.
CURRENCY,

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

Defendant.

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2:16-MC-00192-MCE-CKD

It is hereby stipulated by and between the United States of America and claimants Ellena

18 Jackson (“Jackson”) and Mike Pool (“Pool”), by and through their respective counsel, as follows:
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1.

On or about September 22, 2016, claimants Jackson and Pool filed claims in the

20 administrative forfeiture proceedings with the United States Postal Inspection Service with respect to
21 the Approximately $7,000.00 in U.S. Currency. (hereafter “defendant currency”), which was seized on
22 July 7, 2016.
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2.

The United States Postal Inspection Service has sent the written notice of intent to forfeit

24 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
25 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person
26 other than the claimant has filed a claim to the defendant currency as required by law in the
27 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
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Stipulation to Extend Time to File Complaint

1 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
2 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
3 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
4 the parties. That deadline is December 21, 2016.
4.

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

6 January 20, 2017, the time in which the United States is required to file a civil complaint for forfeiture
7 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
8 subject to forfeiture.
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Accordingly, the parties agree that the deadline by which the United States shall be

10 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
11 alleging that the defendant currency is subject to forfeiture shall be extended to January 20, 2017.
12 Dated:

12/20/2016

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PHILLIP A. TALBERT
United States Attorney
/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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17 Dated:

12/20/2016

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/s/ Justin L. Ward
JUSTIN L. WARD
Attorney for claimants Ellena
Jackson and Mike Pool
(Authorized via phone)

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ORDER
Pursuant to the above stipulation, the time in which the United States is required to file a civil

23 complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the
24 defendant currency is subject to forfeiture shall be extended to January 20, 2017.
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IT IS SO ORDERED.
Dated: January 5, 2017

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Stipulation to Extend Time to File Complaint