United States of America v. $257,258.00 Maintained at American River Bank, Account Number 310042213, held in the name of Time Enterprises, LLC et al

Filing 2

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 10/11/17: 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 January 8, 2018. (Kaminski, H)

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1 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 2 3 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 2:17-MC-00149-KJM-CKD 14 15 $257,258.00 MAINTAINED AT AMERICAN RIVER BANK, ACCOUNT NUMBER 310042213, HELD IN THE NAME OF TIME ENTERPRISES, LLC; STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE 16 17 18 $99,947.00 MAINTAINED AT WELLS FARGO BANK, ACCOUNT NUMBER 6311698424, HELD IN THE NAME OF MERON, INC., DBA: WOW IMAGING PRODUCTS; 19 20 21 22 23 $293,568.00 MAINTAINED AT WELLS FARGO BANK, ACCOUNT NUMBER 6038669990, HELD IN THE NAME OF MICHAEL AND ERIN LOWE; $24,502.00 MAINTAINED AT WELLS FARGO BANK, ACCOUNT NUMBER 0390560696, HELD IN THE NAME OF MICHAEL AND ERIN LOWE; and 24 25 26 27 $1,050,000.00 MAINTAINED AT FIDELITY INVESTMENTS, ACCOUNT NUMBER 676411771, HELD IN THE NAME JIMMY A. MERON FAMILY TRUST. Defendants. 28 1 Stipulation to Extend Time to File Complaint 1 It is hereby stipulated by and between the United States of America and potential claimants 2 Jimmy Meron and Michael Lowe (“potential claimants”), by and through their respective counsel, as 3 follows: 4 1. On July 12, 2017, agents with the General Services Administration – Office of Inspector 5 General (“GSA-OIG”) seized the above listed assets held in the names of potential claimants Jimmy 6 Meron and Michael Lowe. 7 2. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for 8 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant 9 currency is subject to forfeiture within ninety days after seizure, unless the court extends the deadline 10 for good cause shown or by agreement of the parties. That deadline is October 10, 2017. 11 3. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to 12 January 8, 2018, the time in which the United States is required to file a civil complaint for forfeiture 13 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 14 subject to forfeiture. 15 4. Accordingly, the parties agree that the deadline by which the United States shall be 16 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 17 alleging that the defendant currency is subject to forfeiture shall be extended to January 8, 2018. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 2 Stipulation to Extend Time to File Complaint 1 Dated: 10/5/17 PHILLIP A. TALBERT United States Attorney 2 3 By: 4 /s/ Andre M. Espinosa ANDRE M. ESPINOSA KEVIN C. KHASIGIAN Assistant U.S. Attorney 5 6 Dated: 10-4-17 /s/ Kenneth L. Rosefeld KENNETH L. ROSENFELD Attorney for Jimmy Meron Dated: 10-4-17 /s/ Allen Sawyer ALLEN SAWYER Attorney for Michael Lowe 7 8 9 10 11 12 IT IS SO ORDERED. 13 Dated: October 11, 2017. 14 UNITED STATES DISTRICT JUDGE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Stipulation to Extend Time to File Complaint

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