United States of America v. Approximately $15,000.00 in U.S. Currency

Filing 16

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 4/27/2021 EXTENDING the deadline by which the U.S. shall be required to file a complaint for forfeiture and/or to obtain an indictment against that the defendant currency to 6/18/2021. (Coll, A)

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PHILLIP A. TALBERT
Acting United States Attorney
KEVIN C. KHASIGIAN
Assistant United States 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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2:19-MC-00217-MCE-EFB

Plaintiff,
v.
APPROXIMATELY $15,000.00 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 Ronald

18 Garvin (“claimant”), by and through their respective counsel, as follows:
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1.

On or about August 27, 2019, claimant filed a claim in the administrative forfeiture

20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $15,000.00 in U.S.
21 Currency (hereafter “defendant currency”), which was seized on June 6, 2019.
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2.

The U.S. Postal Inspection Service has sent the written notice of intent to forfeit required

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

27 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency
28 is subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
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Stipulation and Order to Extend Time
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1 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
2 That deadline was November 25, 2019.
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4.

By Stipulation and Order filed January 6, 2020, the parties stipulated to extend to February

4 21, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
5 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
6 forfeiture.
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5.

By Stipulation and Order filed February 21, 2020, the parties stipulated to extend to May

8 21, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
10 forfeiture.
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6.

By Stipulation and Order filed May 21, 2020, the parties stipulated to extend to August 19,

12 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
13 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
14 forfeiture.
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7.

By Stipulation and Order filed August 17, 2020, the parties stipulated to extend to October

16 19, 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
17 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
18 forfeiture.
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8.

By Stipulation and Order filed October 22, 2020, the parties stipulated to extend to January

20 18, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
21 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
22 forfeiture.
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9.

By Stipulation and Order filed January 13, 2021, the parties stipulated to extend to February

24 17, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
25 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
26 forfeiture.
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10.

By Stipulation and Order filed February 12, 2021, the parties stipulated to extend to April

28 19, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
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Stipulation and Order to Extend Time
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1 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
2 forfeiture.
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11.

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

4 18, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
5 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
6 forfeiture.
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12.

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

8 to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that
9 the defendant currency is subject to forfeiture shall be extended to June 18, 2021.
10 Dated: 4/16/21

PHILLIP A. TALBERT
Acting United States Attorney

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By:
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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant United States Attorney

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14 Dated: 4/16/21
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/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for potential claimant
Ronald Garvin
(Signature authorized by email)

IT IS SO ORDERED.

18 Dated: April 27, 2021
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Stipulation and Order to Extend Time