United States of America v. Approximately $9,960.00 in U.S. Currency

Filing 14

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 3/31/2021 EXTENDING time to 5/5/2021, for the United States to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture. (Tupolo, 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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Plaintiff,
v.
APPROXIMATELY $9,960.00 IN
U.S. CURRENCY,

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

Defendant.

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2:20-MC-00073-TLN-CKD

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

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

On or about January 10, 2020, claimant filed a claim in the administrative forfeiture

20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $9,960.00 in U.S.
21 Currency (hereafter “defendant currency”), which was seized on October 26, 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

1 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
2 That deadline was April 9, 2020.
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4.

By Stipulation and Order filed April 1, 2020, the parties stipulated to extend to July 8, 2020,

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

By Stipulation and Order filed July 1, 2020, the parties stipulated to extend to September 7,

7 2020, the time in which the United States is required to file a civil complaint for forfeiture against the
8 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
9 forfeiture.
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6.

By Stipulation and Order filed September 3, 2020, the parties stipulated to extend to

11 November 6, 2020, the time in which the United States is required to file a civil complaint for forfeiture
12 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject
13 to forfeiture.
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7.

By Stipulation and Order filed October 30, 2020, the parties stipulated to extend to January

15 5, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
16 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
17 forfeiture.
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8.

By Stipulation and Order filed December 31, 2020, the parties stipulated to extend to March

19 6, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
20 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
21 forfeiture.
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9.

By Stipulation and Order filed March 3, 2021, the parties stipulated to extend to April 5,

23 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
24 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
25 forfeiture.
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10.

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

27 May 5, 2021, the time in which the United States is required to file a civil complaint for forfeiture against
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2

Stipulation and Order to Extend Time

1 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
2 forfeiture.
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11.

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

4 to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that
5 the defendant currency is subject to forfeiture shall be extended to May 5, 2021.
6 Dated: 3/31/2021

PHILLIP A. TALBERT
Acting United States Attorney

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By:

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/s/ Jacek W. Lentz
JACEK W. LENTZ
Attorney for potential claimant
Tunisha Vance

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(Signature authorized by phone)

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Dated: 3/31/2021

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

IT IS SO ORDERED.
Dated: March 31, 2021

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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time