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)

Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 1 of 6

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PHILLIP A. TALBERT
Acting 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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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,

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Stipulation and Order to Extend Time

Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 2 of 6

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APPROXIMATELY $22,852.67 SEIZED
FROM 1ST BANK, A DIVISION OF
GLACIER BANK, ACCOUNT NUMBER
910600008915,

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APPROXIMATELY $21,492.09 SEIZED
FROM WYOCHEM FEDERAL CREDIT
UNION ACCOUNT NUMBER 37648 (S9),

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APPROXIMATELY $12,397.47 SEIZED
FROM HIGH DESERT BANK ACCOUNT
NUMBER 4042002813,

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APPROXIMATELY $8,209.08 SEIZED
FROM HIGH DESERT BANK ACCOUNT
NUMBER 4042002826,

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APPROXIMATELY $6,350.56 SEIZED
FROM PATELCO CREDIT UNION
ACCOUNT NUMBER 473661,

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APPROXIMATELY $7,717.13 SEIZED
FROM UMPQUA BANK ACCOUNT
NUMBER 4863921948,

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APPROXIMATELY $3,213.75 SEIZED
FROM SAFE CREDIT UNION ACCOUNT
NUMBER 822910 (9),

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APPROXIMATELY $10,857.37 SEIZED
FROM TRI COUNTIES BANK
ACCOUNT NUMBER 491039991,

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APPROXIMATELY $6,798.26 SEIZED
FROM EL DORADO SAVINGS BANK
ACCOUNT NUMBER 0053012902,

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2015 MERCEDES-BENZ, ML350, VIN:
4JGDA5HB9FA479275,
2016 FORD, F150 SUPER CAB PICKUP,
VIN: 1FTFX1EGXGKG04896, and

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2017 FORD, F250 SUPER DUTY PICKUP,
VIN: 1FT7X2BT6HEB22700,

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Defendants.

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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
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Stipulation and Order to Extend Time

Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 3 of 6

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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.
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(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.
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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.
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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.
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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.
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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.
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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.
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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
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Stipulation and Order to Extend Time
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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Stipulation and Order to Extend Time
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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.
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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.
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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.
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Stipulation and Order to Extend Time

Case 2:18-mc-00013-WBS-AC Document 30 Filed 07/20/21 Page 6 of 6

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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

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

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8 Dated: 7/15/2021
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/s/ Thomas A. Johnson
THOMAS A. JOHNSON
Attorney for Potential Claimant
James Mecham

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11 Dated: 7/15/2021
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/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for Potential Claimant
Kurt D. Stocks

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14 Dated: 7/16/2021
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/s/ Benjamin Galloway
BENJAMIN GALLOWAY
Attorney for Potential Claimant
Heidi Edwards

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(Signatures authorized by email)
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IT IS SO ORDERED.

19 Dated: July 19, 2021
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Stipulation and Order to Extend Time