United States of America v. Approximately $25,000.00 in U.S. Currency

Filing 14

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 5/15/18 ORDERING that 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 is EXTENDED to 6/29/18. (Becknal, R)

4

McGREGOR W. SCOTT
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

5

Attorneys for the United States

1
2
3

6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,

12
13
14

Plaintiff,
v.

2:17-MC-00162-KJM-CKD
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $25,000.00 IN U.S.
CURRENCY,

15
Defendant.
16
17

It is hereby stipulated by and between the United States of America and potential claimant Tyler

18 Stewart (“claimant”), by and through their respective counsel, as follows:
19

1.

On or about August 2, 2017, claimant filed a claim in the administrative forfeiture

20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $25,000.00 in U.S.
21 Currency (hereafter “defendant currency”), which was seized on May 22, 2017.
22

2.

The U.S. Postal Inspection Service has sent the written notice of intent to forfeit required

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

3.

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

27 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
28 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
1

Stipulation and Order to Extend Time

1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
2 parties. That deadline was October 31, 2017.
3

4.

By Stipulation and Order filed November 6, 2017, the parties stipulated to extend to

4 December 29, 2017, the time in which the United States is required to file a civil complaint for forfeiture
5 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
6 subject to forfeiture.
7

5.

By Stipulation and Order filed January 16, 2018, the parties stipulated to extend to

8 January 29, 2018, the time in which the United States is required to file a civil complaint for forfeiture
9 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
10 subject to forfeiture.
11

6.

By Stipulation and Order filed January 22, 2018, the parties stipulated to extend to

12 February 28, 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

7.

By Stipulation and Order filed February 28, 2018, the parties stipulated to extend to

16 March 30, 2018, the time in which the United States is required to file a civil complaint for forfeiture
17 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
18 subject to forfeiture.
19

8.

By Stipulation and Order filed April 3, 2018, the parties stipulated to extend to April 30,

20 2018, the time in which the United States is required to file a civil complaint for forfeiture against the
21 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
22 forfeiture.
23

9.

By Stipulation and Order filed May 1, 2018, the parties stipulated to extend to May 30,

24 2018, the time in which the United States is required to file a civil complaint for forfeiture against the
25 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
26 forfeiture.
27

10.

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

28 to June 29, 2018, the time in which the United States is required to file a civil complaint for forfeiture
2

Stipulation and Order to Extend Time

1 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
2 subject to forfeiture.
3

11.

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

4 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
5 alleging that the defendant currency is subject to forfeiture shall be extended to June 29, 2018.
6 Dated: 5/14/18

McGREGOR W. SCOTT
United States Attorney

7
By:
8

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

9
10 Dated: 5/11/18
11

/s/ Jennifer Granger
JENNIFER GRANGER
Attorney for potential claimant
Tyler Stewart

12
(Signature authorized by email)
13
14

IT IS SO ORDERED.

15 Dated: 5/15/18
16

UNITED STATES DISTRICT JUDGE

17
18
19
20
21
22
23
24
25
26
27
28
3

Stipulation and Order to Extend Time