USA v. Approx. $28,000.00 in U.S. Currency

Filing 4

ORDER signed by District Judge Troy L. Nunley on 7/16/2021 EXTENDING to 10/18/2021, that the deadline by which the U.S. 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. (Reader, L)

Case 2:21-mc-00109-TLN-JDP Document 4 Filed 07/19/21 Page 1 of 2

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PHILLIP A. TALBERT
Acting 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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Plaintiff,
v.
APPROXIMATELY $28,000.00 IN
U.S. CURRENCY,

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

Defendant.

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2:21-MC-00109-TLN-JDP

It is hereby stipulated by and between the United States of America and potential claimant Meuy

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

On or about January 20, 2021, claimant filed a claim in the administrative forfeiture

20 proceeding with the United States Postal Inspection Service (“USPIS”) with respect to the Approximately
21 $28,000.00 in U.S. Currency (hereafter “defendant currency”), which was seized on October 26, 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

Case 2:21-mc-00109-TLN-JDP Document 4 Filed 07/19/21 Page 2 of 2

1 proceeding, unless the court extends the deadline for good cause shown or by agreement of the parties.
2 That deadline was April 20, 2021.
4.

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By Stipulation and Order filed April 21, 2021, the parties stipulated to extend to July 19,

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

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

8 18, 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.
6.

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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 October 18, 2021.
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15 Dated:

07/16/2021

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PHILLIP A. TALBERT
Acting United States Attorney
By:

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

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20 Dated:

07/16/2021

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/s/ Steve Whitworth
STEVEN A. WHITWORTH
Attorney for potential claimant
Meuy Saephan
(Signature authorized by email)

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IT IS SO ORDERED.
Dated: July 16, 2021

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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Time