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

Filing 6

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 10/6/2017 GRANTING Extension of Time to 12/4/2017 to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment. (Hunt, G)

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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,
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,

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Defendant.
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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:
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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.
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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.
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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
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Stipulation and Order to Extend Time
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1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
2 parties. That deadline was August 3, 2017.
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4.

By Stipulation and Order filed July 31, 2017, the parties stipulated to extend to September

4 5, 2017, the time in which the United States is required to file a civil complaint for forfeiture against the
5 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
6 forfeiture.
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5.

By Stipulation and Order filed September 7, 2017, the parties stipulated to extend to

8 October 5, 2017, the time in which the United States is required to file a civil complaint for forfeiture
9 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
10 subject to forfeiture.
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6.

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

12 to December 4, 2017, the time in which the United States is required to file a civil complaint for
13 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
14 currency is subject to forfeiture.
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7.

Accordingly, the parties agree that the deadline by which the United States shall be

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Stipulation and Order to Extend Time

1 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
2 alleging that the defendant currency is subject to forfeiture shall be extended to December 4, 2017.
3 Dated: 10/5/17

PHILLIP A. TALBERT
United States Attorney

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

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7 Dated: 10/5/17
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/s/ Frank Sullivan
FRANK SULLIVAN
Attorney for potential claimant
Jalen Angel

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(Signature authorized by phone)
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IT IS SO ORDERED.

14 Dated: October 6, 2017
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Stipulation and Order to Extend Time