United States of America v. Approximately $10,270.00 in U.S. Currency et al

Filing 2

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/14/18 ORDERING that the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture shall be EXTENDED to 3/16/2018. (Mena-Sanchez, L)

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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,
v.

2:18-MC-00018-TLN-CKD
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $10,270.00 IN U.S.
CURRENCY, and

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APPROXIMATELY $6,100.00 IN U.S.
CURRENCY,

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Defendants.

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It is hereby stipulated by and between the United States of America and potential claimants Hugo

20 Huazo Jardinez, Blanca Parra Castillo, Jorge Guzman-Aguilar, and Florencia Huazo Jardinez
21 (“claimants”), by and through their respective counsel, as follows:
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1.

On or about November 20, 2017, claimants filed claims in the administrative forfeiture

23 proceeding with the Drug Enforcement Administration with respect to the Approximately $10,270.00 in
24 U.S. Currency and Approximately $6,100.00 in U.S. Currency (hereafter “defendant currency”), which
25 were seized on September 28, 2017.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

27 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
28 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person, other
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Stipulation and Order to Extend Time
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1 than claimants, has filed a claim to the defendant currency as required by law in the administrative
2 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

4 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
5 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
6 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
7 parties. That deadline is February 16, 2018.
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4.

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

9 March 16, 2018, the time in which the United States is required to file a civil complaint for forfeiture
10 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
11 subject to forfeiture.
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5.

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

13 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
14 alleging that the defendant currency is subject to forfeiture shall be extended to March 16, 2018.
15 Dated: 2/13/18

McGREGOR W. SCOTT
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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20 Dated: 2/13/18

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/s/ Arturo A. Marquez
ARTURO A. MARQUEZ
Attorney for potential claimants Hugo Huazo
Jardinez, Blanca Parra Castillo, Jorge GuzmanAguilar, and Florencia Huazo Jardinez

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(Signature authorized by phone)

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IT IS SO ORDERED.

26 Dated: February 14, 2018
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Troy L. Nunley
United States District Judge
Stipulation and Order to Extend Time