United States of America v. Approximately $10,270.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 11/27/2017 EXTENDING Time to 12/14/2017, for the United States to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture. (York, M)

1 PHILLIP A. TALBERT
United States Attorney
2 KEVIN C. KHASIGIAN
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
5 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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11 UNITED STATES OF AMERICA,
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Plaintiff,

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v.

14 APPROXIMATELY $10,270.00 IN U.S.
CURRENCY,
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Defendant.
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2:17-MC-00174-MCE-AC
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

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

18 William “Bill” Byron (“Byron”), by and through their respective counsel, as follows:
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1.

On or about August 16, 2017, claimant Byron filed a claim in the administrative

20 forfeiture proceedings with the United States Postal Inspection Service with respect to the
21 Approximately $10,270.00 in U.S. Currency. (hereafter “defendant currency”), which was seized on
22 May 23, 2017.
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2.

The United States Postal Inspection Service has sent the written notice of intent to forfeit

24 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
25 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person
26 other than the claimant has filed a claim to the defendant currency as required by law in the
27 administrative forfeiture proceeding.
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3.

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

1 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
2 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
3 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
4 the parties. That deadline is November 14, 2017.
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4.

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

6 extend to December 14, 2017, the time in which the United States is required to file a civil complaint
7 for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
8 currency is subject to forfeiture.
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5.

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

10 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
11 alleging that the defendant currency is subject to forfeiture shall be extended to December 14, 2017.
12 Dated:

11/8/2017

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PHILLIP A. TALBERT
United States Attorney
/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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17 Dated:
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11/8/2017

/s/ Candice L. Fields
CANDICE L. FIELDS
Attorney for claimant
William “Bill” Byron
(Authorized via email)

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Stipulation to Extend Time to File Complaint

ORDER

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Pursuant to the stipulation of the parties and good cause appearing, it is hereby ordered that the

3 deadline by which the United States shall be required to file a complaint for forfeiture against the
4 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
5 forfeiture is extended to December 14, 2017.
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IT IS SO ORDERED.

7 Dated: November 27, 2017
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Stipulation to Extend Time to File Complaint