United States of America v. Approximately $9,000.00 in U.S. Currency et al

Filing 11

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 10/14/2020 GRANTING the United States until 11/9/2020 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. (Kastilahn, A)

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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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2:20-MC-00075-KJM-DB

Plaintiff,
v.
APPROXIMATELY $9,000.00 IN
U.S. CURRENCY, AND

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

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APPROXIMATELY $7,200.00 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 claimant Charles

20 Isles (“claimant”), appearing in propria persona, as follows:
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1.

On or about January 14, 2020, claimant filed a claim in the administrative forfeiture

22 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $9,000.00 in U.S.
23 Currency and Approximately $7,200.00 in U.S. Currency (hereafter “defendant currency”), which were
24 seized on October 25, 2019.
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2.

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

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

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3.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for

2 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency
3 is subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
4 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
5 That deadline was April 13, 2020.
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4.

By Stipulation and Order filed April 7, 2020, the parties stipulated to extend to July 10,

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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5.

By Stipulation and Order filed July 10, 2020, the parties stipulated to extend to August 10,

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

By Stipulation and Order filed August 10, 2020, the parties stipulated to extend to

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

By Stipulation and Order filed September 15, 2020, the parties stipulated to extend to

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

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

23 November 9, 2020, the time in which the United States is required to file a civil complaint for forfeiture
24 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject
25 to forfeiture.
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Stipulation and Order to Extend Time

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9.

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

2 to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that
3 the defendant currency is subject to forfeiture shall be extended to November 9, 2020.
4 Dated: 10/8/2020

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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8 Dated: 10/7/2020
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/s/ Charles Isles
CHARLES ISLES
Potential Claimant
Appearing in propria persona
(Signature authorized by phone)

IT IS SO ORDERED.
Dated: October 14, 2020.

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Stipulation and Order to Extend Time