USA v. Approx. $19,980.00 in U.S. Currency et al
Filing
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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.)
Case 2:21-mc-00213-MCE-CKD Document 2 Filed 09/07/21 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: (916) 554-2700
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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-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
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APPROXIMATELY $15,000.00 IN
U.S. CURRENCY, AND
APPROXIMATELY $4,335.00 IN
U.S. CURRENCY,
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Defendant.
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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:
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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.
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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
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Stipulation and Order to Extend Time
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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.
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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.
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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 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.
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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 1, 2021.
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15 Dated:
9/1/21
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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9/1/21
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/s/ Valery Nechay
VALERY NECHAY
Attorney for potential claimant
Jason Brewer
(Signature authorized by phone)
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IT IS SO ORDERED.
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Dated: September 7, 2021
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Stipulation and Order to Extend Time
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