United States of America v. Approximately $9,960.00 in U.S. Currency

Filing 4

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 12/28/17 EXTENDING time for filing a complaint for forfeiture and/or to obtain an indictment alleging forfeiture to 1/29/2018. (Mena-Sanchez, L)

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4 PHILLIP A. TALBERT United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 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-00163-WBS-KJN STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE APPROXIMATELY $9,960.00 IN U.S. CURRENCY, 15 Defendant. 16 17 It is hereby stipulated by and between the United States of America and potential claimant 18 Brookelyn Nigro (“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 $9,960.00 in U.S. 21 Currency (hereafter “defendant currency”), which was seized on May 16, 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 29 30 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 October 31, 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. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 8 to 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. Accordingly, the parties agree that the deadline by which the United States shall be 12 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 13 alleging that the defendant currency is subject to forfeiture shall be extended to January 29, 2018. 14 Dated: 12/27/17 PHILLIP A. TALBERT United States Attorney 15 By: 16 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney 17 18 19 Dated: 12/27/17 20 /s/ Jennifer Granger JENNIFER GRANGER Attorney for potential claimant Brookelyn Nigro 21 (Signature authorized by email) 22 23 24 25 IT IS SO ORDERED. Dated: December 28, 2017 26 27 28 29 30 2 Stipulation and Order to Extend Time

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