USA v. Approximately $19,900.00 in U.S. Currency

Filing 11

ORDER signed by Senior Judge Morrison C. England, Jr. on 2/17/2021 EXTENDING to 3/18/2021. that the deadline by which the U.S. 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.(Reader, L)

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MCGREGOR W. SCOTT
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,

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v.

2:20-MC-00093 MCE EFB

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APPROXIMATELY $19,900.00 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 Anthony Clark (“Clark”), by and through their respective counsel, as follows:
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1.

On or about February 20, 2020, claimant Clark filed a claim in the administrative

20 forfeiture proceedings with the Drug Enforcement Administration with respect to the Approximately
21 $19,900.00 in U.S. Currency (hereafter “defendant currency”), which was seized on November 21, 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 person
24 to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than
25 the claimant has filed a claim to the defendant currency as required by law in the administrative forfeiture
26 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 May 20, 2019.
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4.

By Stipulation and Order filed April 16, 2020, the parties stipulated to extend to August

5 18, 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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5.

By Stipulation and Order filed August 18, 2020, the parties stipulated to extend to

9 November 16, 2020, the time in which the United States is required to file a civil complaint for forfeiture
10 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
11 subject to forfeiture.
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6.

By Stipulation and Order filed November 16, 2020, the parties stipulated to extend to

13 January 15, 2021, the time in which the United States is required to file a civil complaint for forfeiture
14 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
15 subject to forfeiture.
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7.

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

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

21 to March 18, 2021, the time in which the United States is required to file a civil complaint for forfeiture
22 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
23 subject to forfeiture.
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Stipulation to Extend Time to File Complaint

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9.

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

2 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
3 alleging that the defendant currency is subject to forfeiture shall be extended to March 18, 2021.
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Dated:

2/12/2021

MCGREGOR W. SCOTT
United States Attorney

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

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Dated:

2/12/2021

/s/ Robert J. Beles
ROBERT J. BELES
Beles & Beles Law Office
Attorney for Christopher Anthony
Clark
(As authorized via email)

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IT IS SO ORDERED.
Dated: February 17, 2021

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Stipulation to Extend Time to File Complaint