USA v. Approximately $28,360.00 in U.S. Currency

Filing 8

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 9/14/2020 GRANTING the United States until 10/13/2020 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. (Coll, A)

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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.

2:20-MC-00082-KJM-EFB

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APPROXIMATELY $28,360.00 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 Christopher Reyes (“Reyes”), appearing in propria persona, hereby agree and STIPULATE as follows:
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1.

On or about January 15, 2019, claimant Reyes filed a claim in the administrative

20 forfeiture proceedings with the Drug Enforcement Administration with respect to the Approximately
21 $28,360.00 in U.S. Currency (hereafter “defendant currency”), which was seized on October 22, 2019.
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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

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 April 14, 2020.
4.

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By Stipulation and Order filed April 10, 2020, the parties stipulated to extend to July 14,

5 2020, 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.
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By Stipulation and Order filed July 10, 2020, the parties stipulated to extend to August

9 14, 2020, the time in which the United States is required to file a civil complaint for forfeiture against
10 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
11 forfeiture.
6.

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

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

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

17 extend to October 13, 2020, the time in which the United States is required to file a civil complaint for
18 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
19 currency is subject to forfeiture.
8.

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

21 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
22 alleging that the defendant currency is subject to forfeiture shall be extended to October 13, 2020.
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Dated:

MCGREGOR W. SCOTT
United States Attorney

9/11/2020

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

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Stipulation to Extend Time to File Complaint

1 Dated: 9/11/2020
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/s/ Christopher Reyes
CHRISTOPHER REYES
Appearing in Propria Persona
(As authorized via phone)

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IT IS SO ORDERED.

6 Dated: September 14, 2020.
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Stipulation to Extend Time to File Complaint