United States of America v. Approximately $66,996.00 in U.S. Currency

Filing 4

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/9/2018 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 5/4/2018. (Fabillaran, J)

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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,

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v.

2:18-MC-00026-TLN-AC

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APPROXIMATELY $66,996.00 IN U.S.
CURRENCY,

STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

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Defendant.
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It is hereby stipulated by and between the United States of America and potential claimant

18 Samir Salem Acho (“Acho”), by and through their respective counsel of record, as follows:
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1.

On or about December 4, 2017, claimant Acho filed a claim in the administrative

20 forfeiture proceedings with the Drug Enforcement Administration with respect to the Approximately
21 $66,996.00 in U.S. Currency (hereafter “defendant currency”), which was seized on July 12, 2017.
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2.

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

23 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
24 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person
25 other than the claimant has filed a claim to the defendant currency as required by law in the
26 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

28 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
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Stipulation to Extend Time to File Complaint
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1 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
2 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of
3 the parties. That deadline was March 4, 2018.
4.

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By Stipulation and Order filed March 2, 2018, the parties stipulated to extend to April 4,

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

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

9 extend to May 4, 2018, the time in which the United States is required to file a civil complaint for
10 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
11 currency is subject to forfeiture.
6.

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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 May 4, 2018.
15 Dated:

4/3/2018

MCGREGOR W. SCOTT
United States Attorney

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

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20 Dated:

4/3/2018

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/s/ Craig Ribbeck
CRAIG K. RIBBECK
Attorney for Samir Salem Acho
(As authorized via phone)

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IT IS SO ORDERED.
Dated: April 9, 2018

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Time to File Complaint