United States of America v. Approximately $8,000.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 7/31/17 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 9/5/17. (Becknal, R)

Download PDF
4 PHILLIP A. TALBERT United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 5 Attorneys for the United States 1 2 3 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, 12 13 14 Plaintiff, v. 2:17-MC-00109-WBS-AC STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE APPROXIMATELY $8,000.00 IN U.S. CURRENCY, 15 Defendant. 16 17 It is hereby stipulated by and between the United States of America and potential claimant Jalen 18 Angel (“claimant”), by and through their respective counsel, as follows: 19 1. On or about May 5, 2017, claimant filed a claim in the administrative forfeiture 20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $8,000.00 in U.S. 21 Currency (hereafter “defendant currency”), which was seized on February 27, 2017. 22 2. The U.S. Postal Inspection Service has sent the written notice of intent to forfeit required 23 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a 24 claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimant 25 has filed a claim to the defendant currency as required by law in the administrative forfeiture proceeding. 26 3. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for 27 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant 28 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative 1 Stipulation and Order to Extend Time 1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the 2 parties. That deadline is August 3, 2017. 3 4. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to 4 September 5, 2017, the time in which the United States is required to file a civil complaint for forfeiture 5 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 6 subject to forfeiture. 7 5. Accordingly, the parties agree that the deadline by which the United States shall be 8 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 9 alleging that the defendant currency is subject to forfeiture shall be extended to September 5, 2017. 10 Dated: 7/28/17 PHILLIP A. TALBERT United States Attorney 11 By: 12 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney 13 14 15 Dated: 7/28/17 16 /s/ Frank Sullivan FRANK SULLIVAN Attorney for potential claimant Jalen Angel 17 (Signature authorized by email) 18 19 20 21 IT IS SO ORDERED. 22 Dated: July 31, 2017 23 24 25 26 27 28 2 Stipulation and Order to Extend Time

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?