USA v. Approximately $117,151.48 seized from Bank of America Account Number 5010 1714 7633 et al

Filing 30

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 7/19/2021 EXTENDING time until 10/18/2021 to file a complaint for forfeiture and/or to obtain an indictment alleging forfeiture. (Huang, H)

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Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 1 of 6 4 PHILLIP A. TALBERT Acting 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 15 16 17 18 19 20 21 22 23 24 25 26 27 2:18-MC-00013-WBS-AC Plaintiff, v. APPROXIMATELY $117,151.48 SEIZED FROM BANK OF AMERICA ACCOUNT NUMBER 5010 1714 7633, STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE APPROXIMATELY $43,882.17 SEIZED FROM BANK OF AMERICA ACCOUNT NUMBER 5010 0170 0675, APPROXIMATELY $5,713.82 SEIZED FROM BANK OF AMERICA ACCOUNT NUMBER 1641 0242 5652, APPROXIMATELY $4,436.39 SEIZED FROM BANK OF AMERICA ACCOUNT NUMBER 5010 1940 4044, APPROXIMATELY $60,328.73 SEIZED FROM UNIWYO FEDERAL CREDIT UNION ACCOUNT NUMBER 61324, APPROXIMATELY $29,438.90 SEIZED FROM MECHANICS BANK ACCOUNT NUMBER 42073421, APPROXIMATELY $23,077.78 SEIZED FROM FIRST CITIZENS BANK ACCOUNT NUMBER 001064426523, 28 29 30 1 Stipulation and Order to Extend Time Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 2 of 6 1 2 APPROXIMATELY $22,852.67 SEIZED FROM 1ST BANK, A DIVISION OF GLACIER BANK, ACCOUNT NUMBER 910600008915, 3 4 APPROXIMATELY $21,492.09 SEIZED FROM WYOCHEM FEDERAL CREDIT UNION ACCOUNT NUMBER 37648 (S9), 5 6 APPROXIMATELY $12,397.47 SEIZED FROM HIGH DESERT BANK ACCOUNT NUMBER 4042002813, 7 8 APPROXIMATELY $8,209.08 SEIZED FROM HIGH DESERT BANK ACCOUNT NUMBER 4042002826, 9 10 APPROXIMATELY $6,350.56 SEIZED FROM PATELCO CREDIT UNION ACCOUNT NUMBER 473661, 11 12 APPROXIMATELY $7,717.13 SEIZED FROM UMPQUA BANK ACCOUNT NUMBER 4863921948, 13 14 APPROXIMATELY $3,213.75 SEIZED FROM SAFE CREDIT UNION ACCOUNT NUMBER 822910 (9), 15 16 APPROXIMATELY $10,857.37 SEIZED FROM TRI COUNTIES BANK ACCOUNT NUMBER 491039991, 17 18 APPROXIMATELY $6,798.26 SEIZED FROM EL DORADO SAVINGS BANK ACCOUNT NUMBER 0053012902, 19 20 21 2015 MERCEDES-BENZ, ML350, VIN: 4JGDA5HB9FA479275, 2016 FORD, F150 SUPER CAB PICKUP, VIN: 1FTFX1EGXGKG04896, and 22 23 2017 FORD, F250 SUPER DUTY PICKUP, VIN: 1FT7X2BT6HEB22700, 24 Defendants. 25 26 It is hereby stipulated by and between the United States of America and potential claimants James 27 Mecham, Kurt D. Stocks, and Heidi Edwards (“claimants”), by and through their respective counsel, as 28 follows: 29 30 2 Stipulation and Order to Extend Time Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 3 of 6 1 1. On or about November 7, 2017, the Internal Revenue Service-Criminal Investigation 2 (“IRS-CI”) seized the above-referenced defendant assets pursuant to Federal seizure warrants. 3 4 (hereinafter collectively “defendant assets”). 2. Under 18 U.S.C. §§ 983(a)(1)(A)(i)-(iv), and 983(a)(3)(A), the United States is required to 5 send notice to potential claimants, file a complaint for forfeiture against the defendant assets, or obtain an 6 indictment alleging that the defendant assets are subject to forfeiture within ninety days of seizure, unless 7 the court extends the deadline for good cause shown or by agreement of the parties. That deadline was 8 February 5, 2018. 9 3. By Stipulation and Order filed February 6, 2018, the parties stipulated to extend to May 4, 10 2018, the time in which the United States is required to file a civil complaint for forfeiture against the 11 defendant assets and/or to obtain an indictment alleging that the defendant assets are subject to forfeiture. 12 4. By Stipulation and Order filed April 26, 2018, the parties stipulated to extend to August 3, 13 2018, the time in which the United States is required to file a civil complaint for forfeiture against the 14 defendant assets and/or to obtain an indictment alleging that the defendant assets are subject to forfeiture. 15 5. By Stipulation and Order filed July 27, 2018, the parties stipulated to extend to 16 November 1, 2018, the time in which the United States is required to file a civil complaint for forfeiture 17 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 18 to forfeiture. 19 6. By Stipulation and Order filed October 25, 2018, the parties stipulated to extend to 20 February 1, 2019, the time in which the United States is required to file a civil complaint for forfeiture 21 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 22 to forfeiture. 23 7. By Stipulation and Order filed January 28, 2019, the parties stipulated to extend to 24 May 1, 2019, the time in which the United States is required to file a civil complaint for forfeiture against 25 the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject to 26 forfeiture. 27 8. By Stipulation and Order filed April 30, 2019, the parties stipulated to extend to 28 July 30, 2019, the time in which the United States is required to file a civil complaint for forfeiture 3 Stipulation and Order to Extend Time 29 30 Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 4 of 6 1 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 2 to forfeiture. 3 9. By Stipulation and Order filed July 29, 2019, the parties stipulated to extend to 4 October 28, 2019, the time in which the United States is required to file a civil complaint for forfeiture 5 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 6 to forfeiture. 7 10. By Stipulation and Order filed October 21, 2019, the parties stipulated to extend to 8 January 27, 2020, the time in which the United States is required to file a civil complaint for forfeiture 9 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 10 to forfeiture. 11 11. By Stipulation and Order filed January 28, 2020, the parties stipulated to extend to 12 April 24, 2020, the time in which the United States is required to file a civil complaint for forfeiture 13 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 14 to forfeiture. 15 12. By Stipulation and Order filed April 15, 2020, the parties stipulated to extend to 16 July 23, 2020, the time in which the United States is required to file a civil complaint for forfeiture 17 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 18 to forfeiture. 19 13 By Stipulation and Order filed July 17, 2020, the parties stipulated to extend to 20 October 21, 2020, the time in which the United States is required to file a civil complaint for forfeiture 21 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 22 to forfeiture. 23 14. By Stipulation and Order filed October 21, 2020, the parties stipulated to extend to 24 January 19, 2021, the time in which the United States is required to file a civil complaint for forfeiture 25 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 26 to forfeiture. 27 15. By Stipulation and Order filed January 20, 2021, the parties stipulated to extend to 28 April 19, 2021, the time in which the United States is required to file a civil complaint for forfeiture 4 Stipulation and Order to Extend Time 29 30 Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 5 of 6 1 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 2 to forfeiture. 3 16. By Stipulation and Order filed April 20, 2021, the parties stipulated to extend to 4 July 19, 2021, the time in which the United States is required to file a civil complaint for forfeiture 5 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 6 to forfeiture. 7 17. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 8 to October 18, 2021, the time in which the United States is required to file a civil complaint for forfeiture 9 against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject 10 to forfeiture. 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 29 30 5 Stipulation and Order to Extend Time Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 6 of 6 1 18. Accordingly, the parties agree that the deadline by which the United States shall be 2 required to file a complaint for forfeiture against the defendant assets and/or to obtain an indictment 3 alleging that the defendant assets are subject to forfeiture shall be extended to October 18, 2021. 4 Dated: 7/19/2021 PHILLIP A. TALBERT Acting United States Attorney 5 By: 6 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney 7 8 Dated: 7/15/2021 9 /s/ Thomas A. Johnson THOMAS A. JOHNSON Attorney for Potential Claimant James Mecham 10 11 Dated: 7/15/2021 12 /s/ Mark J. Reichel MARK J. REICHEL Attorney for Potential Claimant Kurt D. Stocks 13 14 Dated: 7/16/2021 15 /s/ Benjamin Galloway BENJAMIN GALLOWAY Attorney for Potential Claimant Heidi Edwards 16 (Signatures authorized by email) 17 18 IT IS SO ORDERED. 19 Dated: July 19, 2021 20 21 22 23 24 25 26 27 28 29 30 6 Stipulation and Order to Extend Time

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