USA v. Approx. $14,390.00 in U.S. Currency et al

Filing 3

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 7/16/2021 EXTENDING to 8/9/2021 the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant currency and defendant firearms and/or to obtain an indictment alleging that the defendant currency and defendant firearms are subject to forfeiture. (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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Plaintiff,
v.
APPROXIMATELY $14,390.00 IN
U.S. CURRENCY,

2:21-MC-00172-MCE-CKD
STIPULATION AND ORDER EXTENDING TIME
FOR FILING A COMPLAINT FOR FORFEITURE
AND/OR TO OBTAIN AN INDICTMENT
ALLEGING FORFEITURE

JUGGERNAUT JTE15 TACTICAL RIFLE,
MOSSBERG 590 SHOTGUN,

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BLACK ACES TACTICAL PRO SERIES L
SHOTGUN,

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GLOCK 19 PISTOL, AND

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SPRINGFIELD ARMORY 1911 PISTOL,

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Defendants.

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

24 Frandsen (“claimant”), appearing in propria persona, as follows:
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1.

On or about April 11, 2021, claimant filed a claim in the administrative forfeiture

26 proceeding with the Drug Enforcement Administration with respect to the Approximately $14,390.00 in
27 U.S. Currency (hereafter “defendant currency”), Juggernaut JTE15 Tactical Rifle, Mossberg 590
28 Shotgun, Black Aces Tactical Pro Series L Shotgun, Glock 19 Pistol, and Springfield Armory 1911 Pistol
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Stipulation and Order to Extend Time

1 (hereafter “defendant firearms”) which were seized on January 13, 2021.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

3 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
4 person to file a claim to the defendant currency and defendant firearms under 18 U.S.C. § 983(a)(2)(A)5 (E), and no person other than claimant has filed a claim to the defendant currency and defendant firearms
6 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

8 forfeiture against the defendant currency and defendant firearms and/or to obtain an indictment alleging
9 that the defendant currency and defendant firearms are subject to forfeiture within ninety days after a
10 claim has been filed in the administrative forfeiture proceeding, unless the court extends the deadline for
11 good cause shown or by agreement of the parties. That deadline is July 10, 2021.
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4.

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

13 August 9, 2021, the time in which the United States is required to file a civil complaint for forfeiture
14 against the defendant currency and defendant firearms and/or to obtain an indictment alleging that the
15 defendant currency and defendant firearms are subject to forfeiture.
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Stipulation and Order to Extend Time

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5.

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 currency and defendant firearms and/or to
3 obtain an indictment alleging that the defendant currency and defendant firearms are subject to forfeiture
4 shall be extended to August 9, 2021.
5 Dated: 7/7/2021

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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/s/ Robert Frandsen
ROBERT FRANDSEN
Potential Claimant
Appearing in propria persona
1182 Franklin Ave
Yuba City, CA 95991
(Signature authorized by phone)

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IT IS SO ORDERED.

18 Dated: July 16, 2021
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Stipulation and Order to Extend Time