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

Filing 6

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 7/26/18, ORDERING that the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant assets and/or to obtain an indictment alleging that the defendant assets are subject to forfeiture is EXTENDED to 11/1/2018. (Kastilahn, A)

4

McGREGOR W. SCOTT
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

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
1

Stipulation and Order to Extend Time

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:
2

Stipulation and Order to Extend Time

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

(hereinafter collectively “defendant assets”).

4

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.

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

16 to November 1, 2018, the time in which the United States is required to file a civil complaint for
17 forfeiture against the defendant assets and/or to obtain an indictment alleging that the defendant assets are
18 subject to forfeiture.
19

6.

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

20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
3

Stipulation and Order to Extend Time

1 required to file a complaint for forfeiture against the defendant assets and/or to obtain an indictment
2 alleging that the defendant assets are subject to forfeiture shall be extended to November 1, 2018.
3 Dated: 7/26/2018

McGREGOR W. SCOTT
United States Attorney

4
5

By:

6

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

7
8 Dated: 7/25/18
9

/s/ Thomas A. Johnson
THOMAS A. JOHNSON
Attorney for Potential Claimant
James Mecham

10
11 Dated: 7/25/18
12

/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for Potential Claimant
Kurt D. Stocks

13
14 Dated: 7/25/18
15

/s/ Jerome Price for
MATTHEW BOCKMAN
Attorney for Potential Claimant
Heidi Edwards

16
(Signatures authorized by email)
17
18

IT IS SO ORDERED.

19 Dated: July 26, 2018
20
21
22
23
24
25
26
27
28
4

Stipulation and Order to Extend Time