USA v. Approx. $37,000.00 in U.S. Currency

Filing 4

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/12/21 ORDERING that the deadline by which the United States 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 shall be extended to March 24, 2021. (Kaminski, H)

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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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2:20-MC-00314-TLN-DB

Plaintiff,
v.
APPROXIMATELY $37,000.00 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 Kera

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

On or about September 25, 2020, claimant filed a claim in the administrative forfeiture

20 proceeding with the United States Postal Inspection Service (“USPIS”) with respect to the Approximately
21 $37,000.00 in U.S. Currency (hereafter “defendant currency”), which was seized on July 24, 2020.
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2.

The USPIS has sent the written notice of intent to forfeit required by 18 U.S.C. §

23 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the
24 defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimant has filed a claim
25 to the defendant currency as required by law in the 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

27 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency
28 is subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
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Stipulation and Order to Extend Time

1 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
2 That deadline was December 24, 2020.
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4.

By Stipulation and Order filed December 17, 2020, the parties stipulated to extend to

4 February 22, 2021, the time in which the United States is required to file a civil complaint for forfeiture
5 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject
6 to forfeiture.
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5.

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

8 24, 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
10 forfeiture.
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6.

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

12 to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that
13 the defendant currency is subject to forfeiture shall be extended to March 24, 2021.
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15 Dated:

2/12/21

McGREGOR W. SCOTT
United States Attorney

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

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2/12/21

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/s/ Jacek Lentz
JACEK LENTZ
Attorney for potential claimant
Kera Barber
(Signature authorized by email)

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IT IS SO ORDERED.

26 Dated: February 12, 2021

Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time