USA v. Approx. $19,980.00 in U.S. Currency et al

Filing 2

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr. on 9/7/2021 ORDERING that 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 is EXTENDED to 10/1/2021. (Zignago, K.)

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Case 2:21-mc-00213-MCE-CKD Document 2 Filed 09/07/21 Page 1 of 2 4 PHILLIP A. TALBERT Acting United States Attorney KEVIN C. KHASIGIAN Assistant United States Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 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 13 14 2:21-MC-00213-MCE-CKD Plaintiff, v. APPROXIMATELY $19,980.00 IN U.S. CURRENCY, STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE 15 16 17 APPROXIMATELY $15,000.00 IN U.S. CURRENCY, AND APPROXIMATELY $4,335.00 IN U.S. CURRENCY, 18 Defendant. 19 20 It is hereby stipulated by and between the United States of America and potential claimant Jason 21 Brewer (“claimant”), by and through their respective counsel, as follows: 22 1. On or about June 4, 2021, claimant filed a claim in the administrative forfeiture proceeding 23 with the United States Postal Inspection Service (“USPIS”) with respect to the Approximately $19,980.00 24 in U.S. Currency, Approximately $15,000.00 in U.S. Currency and Approximately $4,335.00 in U.S. 25 Currency (hereafter “defendant currency”), which were seized on March 17, 2021. 26 2. The USPIS has sent the written notice of intent to forfeit required by 18 U.S.C. § 27 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the 28 defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimant has filed a claim 1 Stipulation and Order to Extend Time 29 30 Case 2:21-mc-00213-MCE-CKD Document 2 Filed 09/07/21 Page 2 of 2 1 to the defendant currency as required by law in the administrative forfeiture proceeding. 3. 2 Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for 3 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency 4 is 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 is September 2, 2021. 4. 7 As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to October 8 1, 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. 5. 11 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 1, 2021. 14 15 Dated: 9/1/21 PHILLIP A. TALBERT Acting United States Attorney 16 By: 17 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant United States Attorney 18 19 20 Dated: 9/1/21 21 22 /s/ Valery Nechay VALERY NECHAY Attorney for potential claimant Jason Brewer (Signature authorized by phone) 23 IT IS SO ORDERED. 24 Dated: September 7, 2021 25 26 27 28 29 30 2 Stipulation and Order to Extend Time

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