United States of America v. Approximately $9,200.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 10/18/2017 ORDERING that the deadline by which the U.S. shall be required to file a complaint for forfeiture against the defendant properties and/or to obtain an indictment alleging that the defendant properties are subject to forfeiture is EXTENDED to 12/18/2017. (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-00155-WBS-CKD

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APPROXIMATELY $9,200.00 IN U.S.
CURRENCY,

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 potential claimant

18 Richard Anderson (“Anderson”), appearing in propria persona, as follows:
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1.

On or about July 21, 2017 potential claimant Anderson filed a claim in the

20 administrative forfeiture proceedings with the United States Postal Inspection Service with respect to
21 the Approximately $9,200.00 in U.S. Currency. (hereafter “defendant currency”), which was seized on
22 May 23, 2017.
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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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Stipulation to Extend Time to File Complaint

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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for

2 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
3 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
4 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
5 the parties. That deadline is October 19, 2017.
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4.

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

7 December 18, 2017, the time in which the United States is required to file a civil complaint for
8 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
9 currency is subject to forfeiture.
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5.

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

11 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
12 alleging that the defendant currency is subject to forfeiture shall be extended to December 18, 2017.
13 Dated:

10/17/17

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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18 Dated:

10/17/17

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/s/ Richard Anderson
RICHARD ANDERSON
Potential Claimant, In Propria Persona

IT IS SO ORDERED.
Dated: October 18, 2017

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Stipulation to Extend Time to File Complaint