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

Filing 26

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 11/14/2019 EXTENDING time until 1/2/2020 to file a Complaint for Forfeiture and/or to obtain an Indictment alleging forfeiture. (Huang, H)

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MCGREGOR W. SCOTT
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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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 was October 20, 2017.
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4.

By Stipulation and Order filed October 23, 2017, the parties stipulated to extend to

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

By Stipulation and Order filed January 2, 2018, the parties stipulated to extend to

11 January 19, 2017, the time in which the United States is required to file a civil complaint for forfeiture
12 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
13 to forfeiture.
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6.

By Stipulation and Order filed January 19, 2018, the parties stipulated to extend to

15 February 19, 2017, the time in which the United States is required to file a civil complaint for forfeiture
16 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
17 to forfeiture.
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7.

By Stipulation and Order filed February 15, 2018, the parties stipulated to extend to May

19 21, 2018, the time in which the United States is required to file a civil complaint for forfeiture against
20 the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
21 forfeiture.
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8.

By Stipulation and Order filed May 18, 2018, the parties stipulated to extend to August

23 20, 2018, the time in which the United States is required to file a civil complaint for forfeiture against
24 the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
25 forfeiture.
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9.

By Stipulation and Order filed August 13, 2018, the parties stipulated to extend to

27 November 19, 2018, the time in which the United States is required to file a civil complaint for
28 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds
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Stipulation to Extend Time to File Complaint

1 are subject to forfeiture.
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10.

By Stipulation and Order filed October 24, 2018, the parties stipulated to extend to

3 January 18, 2019, the time in which the United States is required to file a civil complaint for forfeiture
4 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
5 to forfeiture.
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11.

By Stipulation and Order filed January 18, 2019, the parties stipulated to extend to

7 March 19, 2019, the time in which the United States is required to file a civil complaint for forfeiture
8 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
9 to forfeiture.
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12.

By Stipulation and Order filed March 20, 2019, the parties stipulated to extend to May

11 20, 2019, the time in which the United States is required to file a civil complaint for forfeiture against
12 the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
13 forfeiture.
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13.

By Stipulation and Order filed May 21, 2019, the parties stipulated to extend to July 19,

15 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
16 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
17 forfeiture.
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14.

By Stipulation and Order filed July 17, 2019, the parties stipulated to extend to

19 September 17, 2019, the time in which the United States is required to file a civil complaint for
20 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds
21 are subject to forfeiture.
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15.

By Stipulation and Order filed September 13, 2019, the parties stipulated to extend to

23 November 18, 2019, the time in which the United States is required to file a civil complaint for
24 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds
25 are subject to forfeiture.
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16.

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

27 extend to January 2, 2020, the time in which the United States is required to file a civil complaint for
28 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
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Stipulation to Extend Time to File Complaint

1 funds are subject to forfeiture.
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16.

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

3 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
4 alleging that the defendant funds are subject to forfeiture shall be extended to January 2, 2020.
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Dated:

11/14/2019

MCGREGOR W. SCOTT
United States Attorney

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

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Dated:

11/14/2019

/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: November 14, 2019

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint