United States of America v. Approximately $14,340.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 04/19/17 ORDERING that 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 06/19/17. (Benson, A)

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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 $14,340.00 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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2:17-MC-00070-MCE-KJN

It is hereby stipulated by and between the United States of America and claimant Eduardo

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

On or about September January 20, 2017, claimant Miranda filed claims in the

20 administrative forfeiture proceedings with the United States Postal Inspection Service with respect to
21 the Approximately $14,340.00 in U.S. Currency. (hereafter “defendant currency”), which was seized
22 on November 1, 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 April 20, 2017.
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 June 19, 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 19, 2017.
12 Dated:

4/19/2017

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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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Dated:

4/18/2017

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/s/ Jesse Ortiz
JESSE ORTIZ
Attorney for claimant
Eduardo Miranda
(Authorized via email)

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IT IS SO ORDERED.
Dated: April 19, 2017

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Stipulation to Extend Time to File Complaint