United States of America v. Approximately $138,531.79 in Escrow Proceeds of 2306 Nightingale Ave., Stockton, California

Filing 2

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 3/2/2017 ORDERING 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 6/6/2017.(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.

2:17-MC-00039-WBS-CKD

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APPROXIMATELY $138,531.79 IN
ESCROW PROCEEDS OF 2306
NIGHTINGALE AVE., STOCKTON,
CALIFORNIA,

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 claimant Janet

19 Paniagua (“claimant” or “Paniagua”), by and through their respective counsel, as follows:
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1.

On or about December 8, 2016, claimant Paniagua filed a claim in the administrative

21 forfeiture proceedings with the Federal Bureau of Investigation (“FBI”) with respect to the
22 Approximately $138,531.79 in Escrow Proceeds of 2306 Nightingale Ave., Stockton, California
23 hereafter “defendant currency”), which was seized on September 2, 2016.
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2.

The FBI has sent the written notice of intent to forfeit required by 18 U.S.C. §

25 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the
26 defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed
27 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
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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 March 8, 2017.
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As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to

6 June 6, 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.
5.

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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 June 6, 2017.
12 Dated:

3/2/17

PHILLIP A. TALBERT
United States Attorney

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

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3/2/17

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/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for Janet Paniagua

IT IS SO ORDERED.
Dated: March 2, 2017

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Stipulation to Extend Time to File Complaint