USA v. Approx. $42,687.68,et al.,

Filing 4

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 2/12/2021 EXTENDING time until 4/13/2021 to file a Complaint for Forfeiture and/or to obtain an Indictment alleging forfeiture. (Huang, H)

4

McGREGOR W. SCOTT
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

5

Attorneys for the United States

1
2
3

6
7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,

12
13
14
15
16
17
18
19
20
21
22
23
24

2:20-MC-00301-WBS-CKD

Plaintiff,
v.
APPROXIMATELY $42,687.68 SEIZED
FROM WELLS FARGO BANK
ACCOUNT NUMBER 320-3742212,

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

APPROXIMATELY $1,840.42 SEIZED
FROM WELLS FARGO BANK
ACCOUNT NUMBER 517-7263489,
APPROXIMATELY $629.84 SEIZED
FROM WELLS FARGO BANK
ACCOUNT NUMBER 532-7107099,
APPROXIMATELY $143.04 SEIZED
FROM WELLS FARGO BANK
ACCOUNT NUMBER 530-4807349,
APPROXIMATELY $50.08 SEIZED
FROM WELLS FARGO BANK
ACCOUNT NUMBER 333-4403940, AND
APPROXIMATELY $16,566.00 IN
U.S. CURRENCY,

25
Defendants.
26
27

It is hereby stipulated by and between the United States of America and potential claimants Pablo

28 Salcedo Jr. and Karina Salcedo (“claimants”), by and through their respective counsel, as follows:
1
Stipulation and Order to Extend Time
29
30

1

1.

On or about September 16, 2020, claimants filed a claim in the administrative forfeiture

2 proceeding with the Federal Bureau of Investigation with respect to the Approximately $42,687.68 seized
3 from Wells Fargo Bank Account Number 320-3742212, Approximately $1,840.42 seized from Wells
4 Fargo Bank Account Number 517-7263489, Approximately $629.84 seized from Wells Fargo Bank
5 Account Number 532-7107099, Approximately $143.04 seized from Wells Fargo Bank Account Number
6 530-4807349, Approximately $50.08 seized from Wells Fargo Bank Account Number 333-4403940, and
7 Approximately $16,566.00 in U.S. Currency, (hereafter “defendant funds”), which were seized on or
8 about June 18, 2020.
9

2.

The Federal Bureau of Investigation has sent the written notice of intent to forfeit required

10 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
11 claim to the defendant funds under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimants has
12 filed a claim to the defendant funds as required by law in the administrative forfeiture proceeding.
13

3.

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

14 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds are
15 subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
16 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
17 That deadline was December 15, 2020.
18

4.

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

19 February 12, 2021, the time in which the United States is required to file a civil complaint for forfeiture
20 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
21 forfeiture.
22

5.

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

23 to April 13, 2021, the time in which the United States is required to file a civil complaint for forfeiture
24 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
25 forfeiture.
26 ///
27 ///
28 ///
29
30

2

Stipulation and Order to Extend Time

1

6.

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 funds and/or to obtain an indictment
3 alleging that the defendant funds are subject to forfeiture shall be extended to April 13, 2021.
4 Dated: 2/11/2021

McGREGOR W. SCOTT
United States Attorney

5
By:
6

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

7
8
9 Dated: 2/11/2021
10

/s/ Melissa Dougherty
MELISSA DOUGHERTY
Attorney for potential claimants
Pablo Salcedo Jr. and Karina Salcedo

11
(Signature authorized by phone)
12
13
14

IT IS SO ORDERED.

15 Dated: February 12, 2021
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

3

Stipulation and Order to Extend Time