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

Filing 70

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/29/2022 EXTENDING the time for filing a Complaint for forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture to 7/29/2022. (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.

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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

Defendant.

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2:17-MC-00157-TLN-KJN

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 Wells
22 Fargo Bank Account Number 2249869062 (hereafter “defendant funds”), which were seized on May 8,
23 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 person
26 to file a claim to the defendant funds under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the
27 claimants have filed a claim to the defendant funds as required by law in the administrative forfeiture
28 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 funds and/or to obtain an indictment alleging that the defendant funds are
3 subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
4 proceedings, unless the court extends the deadline for good cause shown or by agreement of the parties.
5 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 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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5.

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

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

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

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

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

18 21, 2018, the time in which the United States is required to file a civil complaint for forfeiture against the
19 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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8.

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

21 20, 2018, the time in which the United States is required to file a civil complaint for forfeiture against the
22 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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9.

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

24 November 19, 2018, the time in which the United States is required to file a civil complaint for forfeiture
25 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
26 to forfeiture.
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10.

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

28 18, 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
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Stipulation to Extend Time to File Complaint

1 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
2

11.

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

3 19, 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
4 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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12.

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

6 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
7 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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13.

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

9 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
10 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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14.

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

12 17, 2019, the time in which the United States is required to file a civil complaint for forfeiture against the
13 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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15.

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

15 November 18, 2019, 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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16.

By Stipulation and Order filed November 15, 2019, the parties stipulated to extend to

19 January 2, 2020, the time in which the United States is required to file a civil complaint for forfeiture
20 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
21 to forfeiture.
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17.

By Stipulation and Order filed January 3, 2020, the parties stipulated to extend to February

23 28, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
24 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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18.

By Stipulation and Order filed February 27, 2020, the parties stipulated to extend to March

26 30, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
27 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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19.

By Stipulation and Order filed March 26, 2020, the parties stipulated to extend to May 29,
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Stipulation to Extend Time to File Complaint

1 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
2 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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20.

By Stipulation and Order filed May 26, 2020, the parties stipulated to extend to July 28,

4 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
5 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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21.

By Stipulation and Order filed July 24, 2020, the parties stipulated to extend to August

7 27, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
8 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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22.

By Stipulation and Order filed August 26, 2020, the parties stipulated to extend to

10 September 28, 2020, the time in which the United States is required to file a civil complaint for forfeiture
11 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
12 to forfeiture.
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23.

By Stipulation and Order filed September 28, 2020, the parties stipulated to extend to

14 October 28, 2020, the time in which the United States is required to file a civil complaint for forfeiture
15 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
16 to forfeiture.
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24.

By Stipulation and Order filed October 28, 2020, the parties stipulated to extend to

18 December 28, 2020, the time in which the United States is required to file a civil complaint for forfeiture
19 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
20 to forfeiture.
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25.

By Stipulation and Order December 17, 2020, the parties stipulated to extend to February

22 26, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
23 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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26.

By Stipulation and Order February 26, 2021, the parties stipulated to extend to April 27,

25 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
26 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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27.

By Stipulation and Order April 28, 2021, the parties stipulated to extend to May 27, 2021,

28 the time in which the United States is required to file a civil complaint for forfeiture against the defendant
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Stipulation to Extend Time to File Complaint

1 funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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28.

By Stipulation and Order May 27, 2021, the parties stipulated to extend to June 25, 2021,

3 the time in which the United States is required to file a civil complaint for forfeiture against the defendant
4 funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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29.

By Stipulation and Order June 25, 2021, the parties stipulated to extend to July 26, 2021,

6 the time in which the United States is required to file a civil complaint for forfeiture against the defendant
7 funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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30.

By Stipulation and Order July 26, 2021, the parties stipulated to extend to August 26,

9 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
10 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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31.

By Stipulation and Order August 26, 2021, the parties stipulated to extend to September

12 28, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
13 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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32.

By Stipulation and Order September 28, 2021, the parties stipulated to extend to October

15 28, 2021, 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 forfeiture.
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33.

By Stipulation and Order October 28, 2021, the parties stipulated to extend to November

18 29, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
19 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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34.

By Stipulation and Order November 30, 2021, the parties stipulated to extend to February

21 28, 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
22 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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35.

By Stipulation and Order February 25, 2022, the parties stipulated to extend to April 29,

24 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
25 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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36.

By Stipulation and Order April 28, 2022, the parties stipulated to extend to May 30, 2022,

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

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37.

By Stipulation and Order May 26, 2022, the parties stipulated to extend to June 29, 2022,

2 the time in which the United States is required to file a civil complaint for forfeiture against the defendant
3 funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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38.

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

5 to July 29, 2022, the time in which the United States is required to file a civil complaint for forfeiture
6 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
7 to forfeiture.
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39.

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

9 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
10 alleging that the defendant funds are subject to forfeiture shall be extended to July 29, 2022.
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Dated:

6/29/22

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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Dated:

6/29/22

/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: June 29, 2022

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint