United States of America v. Approximately $10,000.00 in U.S. Currency

Filing 6

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/27/2018 ORDERING that time for the USA to File a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture is EXTENDED to 5/22/2018. (Washington, S)

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MCGREGOR W. SCOTT
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.

2:17-MC-00179-TLN-KJN

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APPROXIMATELY $10,000.00 IN U.S.
CURRENCY,

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

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

18 Robert E. Huff (“Huff”), by and through their respective counsel, as follows:
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1.

On or about August 23, 2017, claimant Huff filed a claim in the administrative forfeiture

20 proceedings with the United States Postal Inspection Service with respect to the Approximately
21 $10,000.00 in U.S. Currency (hereafter “defendant currency”), which was seized on May 25, 2017.
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2.

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

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

28 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
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Stipulation to Extend Time to File Complaint
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1 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
2 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
3 the parties. That deadline was November 21, 2017.
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4.

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

5 January 22, 2018, 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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5.

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

9 March 23, 2018, the time in which the United States is required to file a civil complaint for forfeiture
10 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject
11 to forfeiture.
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6.

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

13 extend to May 22, 2018, the time in which the United States is required to file a civil complaint for
14 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
15 currency is subject to forfeiture.
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7.

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

17 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
18 alleging that the defendant currency is subject to forfeiture shall be extended to May 22, 2018.
19 Dated:

3/23/18

MCGREGOR W. SCOTT
United States Attorney

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

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3/23/18

/s/ Stephana L.M. Femino
STEPHANA L.M. FEMINO
Attorney for potential claimant
Robert E. Huff
(Authorized via phone)

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Stipulation to Extend Time to File Complaint

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IT IS SO ORDERED.

2 Dated: March 27, 2018
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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint