USA v. Approx. $879,643.00 in U.S. Currency et al

Filing 4

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 7/15/2021 EXTENDING the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture to 7/1/2021. (Coll, A)

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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]

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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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2:21-MC-00097-MCE-KJN

Plaintiff,
v.
APPROXIMATELY $879,643.00 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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ASSORTED MONEY ORDERS VALUED
AT $6,000.00 IN U.S. CURRENCY,

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Defendants.

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

20 Gonzalez Sanchez and Jose Luis Mendoza Castillo (“claimants”), by and through their respective
21 counsel, as follows:
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1.

On or about January 3, 2021 and January 11, 2021, claimants filed claims in the

23 administrative forfeiture proceeding with the Federal Bureau of Investigation with respect to the
24 Approximately $879,643.00 in U.S. Currency and Assorted Money Orders valued at $6,000.00 in U.S.
25 Currency (hereafter collectively “defendant funds”), which were seized on or about October 1, 2020.
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2.

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

27 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
28 claim to the defendant funds under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimants has
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Stipulation and Order to Extend Time
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1 filed a claim to the defendant funds 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

3 forfeiture against the defendant funds and/or to obtain an indictment alleging that the defendant funds are
4 subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture
5 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
6 That deadline was April 2, 2021.
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4.

By Stipulation and Order filed April 12, 2021, the parties stipulated to extend to July 1,

8 2021, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
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5.

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

11 to August 30, 2021, the time in which the United States is required to file a civil complaint for forfeiture
12 against the defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to
13 forfeiture.
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Stipulation and Order to Extend Time

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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 August 30, 2021.
4 Dated: 6/30/2021

PHILLIP A. TALBERT
Acting 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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8 Dated: 6/30/2021
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/s/ Kenneth Rosenfeld
KENNETH ROSENFELD
Attorney for potential claimant
Maria Gonzalez Sanchez

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/s/ Allen N. Sawyer
ALLEN N. SAWYER
Attorney for potential claimant
Jose Luis Mendoza Castillo

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(Signatures authorized by email)
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IT IS SO ORDERED.

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17 Dated: July 15, 2021
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Stipulation and Order to Extend Time