United States of America v. Approximately $4,300.00 in U.S. Currency

Filing 4

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 3/17/2018 EXTENDING Time to 5/14/2018, for the United States to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture. (York, M)

1 MCGREGOR W. SCOTT
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 $4,300.00 IN U.S.
CURRENCY,
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Defendant.
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2:18-MC-00003-MCE-EFB
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 Alexander Shukla (“Shukla”), appearing in propria persona, as follows:
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1.

On or about October 16, 2017, claimant Shukla filed a claim in the administrative

20 forfeiture proceedings with the United States Postal Inspection Service with respect to the
21 Approximately $4,300.00 in U.S. Currency. (hereafter “defendant currency”), which was seized on
22 August 5, 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 was January 12, 2018.
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4.

By Stipulation and Order filed January 12, 2018, the parties stipulated to extend to

6 March 13, 2018, the time in which the United States is required to file a civil complaint for forfeiture
7 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
8 subject to forfeiture.
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5.

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

10 extend to May 14, 2018, the time in which the United States is required to file a civil complaint for
11 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
12 currency is subject to forfeiture.
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6.

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

14 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
15 alleging that the defendant currency is subject to forfeiture shall be extended to May 14, 2018.
16 Dated:

3/13/2018

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MCGREGOR W. SCOTT
United States Attorney
/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

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21 Dated:
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3/13/2018

/s/ Alexander Shukla
ALEXANDER SHUKLA
Appearing in Propria Persona
(As authorized via phone)

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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, the deadline by which the

3 United States shall be required to file a complaint for forfeiture against the defendant currency and/or to
4 obtain an indictment alleging that the defendant currency is subject to forfeiture is hereby extended to
5 May 14, 2018.
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IT IS SO ORDERED.

7 Dated: March 17, 2018
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Stipulation to Extend Time to File Complaint