United States of America v. Approximately $13,200.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 11/27/2017 EXTENDING Time to 1/16/2018, for the United States to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture. (York, M)

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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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11 UNITED STATES OF AMERICA,

2:17-mc-00176-MCE-KJN

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STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

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Plaintiff,
v.

14 APPROXIMATELY $13,200.00 IN U.S.
CURRENCY,
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Defendant.
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It is hereby stipulated by and between the United States of America and potential claimant Derek

18 Michael Chrans (“claimant”), by and through their respective counsel, as follows:
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1.

On or about August 21, 2017, claimant filed a claim in the administrative forfeiture

20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $13,200.00 in U.S.
21 Currency (hereafter “defendant currency”), which was seized on May 25, 2017.
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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.
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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
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Stipulation and Order to Extend Time
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1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
2 parties. That deadline is November 17, 2017.
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4.

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

4 January 16, 2018, 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.
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5.

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

8 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
9 alleging that the defendant currency is subject to forfeiture shall be extended to January 16, 2018.
10 Dated: 11/16/17
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PHILLIP A. TALBERT
United States Attorney
By:

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

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15 Dated: 11/15/17
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/s/ Monroe D. McWard
MONROE D. MCWARD
Attorney for potential claimant
Derek Michael Chrans
(Signature authorized by email)

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IT IS SO ORDERED.

22 Dated: November 27, 2017
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Stipulation and Order to Extend Time