United States of America v. $42,906.72 seized from Wells Fargo Bank Account Number 2249869062

Filing 2

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/20/17 EXTENDING time for failing a complaint for forfeiture and/or to obtain an indictment alleging forfeiture to 12/19/2017. (Mena-Sanchez, L)

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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-00157-TLN-KJN

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$42,906.72 SEIZED FROM WELLS FARGO
BANK ACCOUNT NUMBER 2249869062,

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 claimants Gregorio

18 Ramirez Castillo and Jennifer Jannette Castillo-Ramirez (“claimants”), by and through their respective
19 counsel, as follows:
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1.

On or about July 24, 2017, claimants filed claims in the administrative forfeiture

21 proceedings with the Drug Enforcement Administration with respect to the $42,906.72 seized from
22 Wells Fargo Bank Account Number 2249869062 (hereafter “defendant currency”), which was seized
23 on May 8, 2017.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

25 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
26 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person
27 other than the claimants have filed a claim to the defendant currency as required by law in the
28 administrative forfeiture proceeding.
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Stipulation to Extend Time to File Complaint

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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 20, 2017.
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As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further

7 extend to December 19, 2017, the time in which the United States is required to file a civil complaint
8 for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
9 currency is subject to forfeiture.
5.

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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 19, 2017.
13 Dated:

10/19/2017

PHILLIP A. TALBERT
United States Attorney

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

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18 Dated:

10/19/2017

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/s/ Yan Shrayberman
YAN SHRAYBERMAN
Attorney for claimants
Gregorio Ramirez Castillo and
Jennifer Jannette Castillo-Ramirez
(Authorized via email)

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IT IS SO ORDERED.
Dated: October 20, 2017

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint