USA v. Approx. $48,500.00 in U.S. Currency

Filing 4

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 4/27/2021 EXTENDING the deadline to file a complaint for forfeiture against the defendant asset and/or to obtain an indictment alleging that the defendant asset is subject to forfeiture to 6/18/2021. (Coll, A)

4

PHILLIP A. TALBERT
Acting 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

Plaintiff,

13

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

v.

14
15

APPROXIMATELY $48,500.00 IN U.S.
CURRENCY,

16
17

2:21-MC-00012-MCE-DB

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

18 Xiaobing Wang, Min Guo, and Lianfeng Li, (“claimants”), by and through their respective counsel as
19 follows:
20

1.

On or about September 23, 2020, the Homeland Security Investigations seized the above-

21 referenced defendant asset pursuant to a State search and seizure warrant (hereafter “defendant asset”).
22

2.

Under 18 U.S.C. §§ 983(a)(1)(A)(i)-(iv), and 983(a)(3)(A), the United States is required

23 to send notice to potential claimants, file a complaint for forfeiture against the defendant currency, or
24 obtain an indictment alleging that the defendant currency is subject to forfeiture within ninety days of
25 seizure, unless the court extends the deadline for good cause shown or by agreement of the parties. That
26 deadline was January 20, 2021.
27

3.

By Stipulation and Order filed January 22, 2021, the parties stipulated to extend to April

28 20, 2021, the time in which the United States is required to file a civil complaint for forfeiture against
29
1
30

Stipulation to Extend Time to File Complaint

1 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
2 forfeiture.
3

4.

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

4 18, 2021, the time in which the United States is required to file a civil complaint for forfeiture against
5 the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
6 forfeiture.
7

5.

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

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

1/19/2021

PHILLIP A. TALBERT
Acting United States Attorney

11
12

By:

13

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

14
15 Dated:

1/19/2021

16
17

/s/ Mark J. Reichel
MARK J. REICHEL
Attorney for Potential Claimants
Xiaobing Wang, Min Guo, and Lianfeng Li
(Signature authorized by email)

18
19

IT IS SO ORDERED.

20 Dated: April 27, 2021
21
22
23
24
25
26
27
28
29
2
30

Stipulation to Extend Time to File Complaint