USA v. Approx. $41,140.00 in U.S. Currency

Filing 2

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 6/10/2020 GRANTING the United States until 6/19/2020 to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture. (Coll, 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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Plaintiff,
v.

2:20-MC-00125-MCE-EFB
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

APPROXIMATELY $41,140.00 IN
U.S. CURRENCY,

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Defendant.
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It is hereby stipulated by and between the United States of America and potential claimant Blake

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

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

20 proceeding with the Drug Enforcement Administration with respect to the Approximately $41,140.00 in
21 U.S. Currency (hereafter “defendant currency”), which was seized on October 31, 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 other
25 than claimant has filed a claim to the defendant currency as required by law in the administrative
26 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 and Order to Extend Time
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1 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
2 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
3 parties. That deadline is May 20, 2020.
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4.

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

5 19, 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.

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

9 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
10 alleging that the defendant currency is subject to forfeiture shall be extended to June 19, 2020.
11 Dated: 5/19/2020

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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16 Dated: 5/19/2020
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/s/ Miles A. Harris
MILES A. HARRIS
Attorney for potential claimant
Blake Crisler
2115 Kern Street 101M
Fresno, CA 93721

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(Signature authorized by phone)
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IT IS SO ORDERED.
Dated: June 10, 2020

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Stipulation and Order to Extend Time