United States of America v. Approximately $12,700.00 in U.S. Currency

Filing 8

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/18/2021 EXTENDING 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 to 12/17/2021. (Rodriguez, E)

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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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2:21-MC-00157-WBS-JDP

Plaintiff,
v.
APPROXIMATELY $12,700.00 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

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

On or about March 23, 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 $12,700.00 in U.S. Currency (hereafter “defendant currency”), which was seized on January 12, 2021.
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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
25 claim 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
28 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
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Stipulation and Order to Extend Time
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1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
2 parties. That deadline was June 21, 2021.
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4.

By Stipulation and Order filed June 21, 2021, the parties stipulated to extend to August

4 20, 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.
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5.

By Stipulation and Order filed August 19, 2021, the parties stipulated to extend to October

8 19, 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.

By Stipulation and Order filed October 19, 2021, the parties stipulated to extend to

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

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

16 December 17, 2021, the time in which the United States is required to file a civil complaint for forfeiture
17 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
18 subject to forfeiture.
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8.

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

20 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
21 alleging that the defendant currency is subject to forfeiture shall be extended to December 17, 2021.
22 Dated: 11/18/21

PHILLIP A. TALBERT
Acting 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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Stipulation and Order to Extend Time

1 Dated: 11/18/21
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/s/ Isaac Safier
ISAAC SAFIER
Attorney for potential claimant
Charles Robert Giglio
(Signature authorized by email)

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IT IS SO ORDERED.

7 Dated: November 18, 2021
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Stipulation and Order to Extend Time