USA v. Approx. $79,527.22 in U.S. Currency et al

Filing 36

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 6/3/2024 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 shall be extended to 06/28/2024. (Clemente Licea, O)

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PHILLIP A. TALBERT
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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2:22-MC-00225-WBS-JDP

Plaintiff,
v.
APPROXIMATELY $79,527.22 IN U.S.
CURRENCY, and

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

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APPROXIMATELY $33,000.00 IN U.S.
CURRENCY,

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Defendants.

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

20 Naranjo Gonzalez (“claimant”), by and through their respective counsel, as follows:
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1.

On or about April 25, 2022, the claimant filed a claim in the administrative forfeiture

22 proceedings with the Federal Bureau of Investigation with respect to the Approximately $79,527.22 in
23 U.S. Currency (hereafter “defendant currency”), which was seized on October 15, 2021.
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2.

On or about May 26, 2022, the claimant filed a claim in the administrative forfeiture

25 proceedings with the Federal Bureau of Investigation with respect to the Approximately $33,000.00 in
26 U.S. Currency (hereafter “defendant currency”), which was seized on March 16, 2022.
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3.

The Federal Bureau of Investigation has sent the written notice of intent to forfeit required

28 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
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Stipulation and Order to Extend Time
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1 claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the
2 claimant has filed a claim to the defendant currency as required by law in the administrative forfeiture
3 proceeding.
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4.

Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for

5 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
6 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
7 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the
8 parties. Those deadlines were July 22, 2022, and August 24, 2022.
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5.

By Stipulation and Order filed July 22, 2022, the parties stipulated to extend to September

10 20, 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
11 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
12 forfeiture.
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6.

By Stipulation and Order filed September 20, 2022, the parties stipulated to extend to

14 November 18, 2022, the time in which the United States is required to file a civil complaint for forfeiture
15 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
16 subject to forfeiture.
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7.

By Stipulation and Order filed November 9, 2022, the parties stipulated to extend to

18 January 17, 2023, the time in which the United States is required to file a civil complaint for forfeiture
19 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
20 subject to forfeiture.
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8.

By Stipulation and Order filed January 17, 2023, the parties stipulated to extend to

22 February 16, 2023, the time in which the United States is required to file a civil complaint for forfeiture
23 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
24 subject to forfeiture.
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9.

By Stipulation and Order filed February 15, 2023, the parties stipulated to extend to

26 March 16, 2023, the time in which the United States is required to file a civil complaint for forfeiture
27 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
28 subject to forfeiture.
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Stipulation and Order to Extend Time

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10.

By Stipulation and Order filed March 21, 2023, the parties stipulated to extend to April

2 14, 2023, the time in which the United States is required to file a civil complaint for forfeiture against the
3 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
4 forfeiture.
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11.

By Stipulation and Order filed April 13, 2023, the parties stipulated to extend to June 13,

6 2023, the time in which the United States is required to file a civil complaint for forfeiture against the
7 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
8 forfeiture.
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12.

By Stipulation and Order filed June 9, 2023, the parties stipulated to extend to August 11,

10 2023, the time in which the United States is required to file a civil complaint for forfeiture against the
11 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
12 forfeiture.
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13.

By Stipulation and Order filed August 21, 2023, the parties stipulated to extend to

14 September 8, 2023, the time in which the United States is required to file a civil complaint for forfeiture
15 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
16 subject to forfeiture.
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14.

By Stipulation and Order filed September 6, 2023, the parties stipulated to extend to

18 October 6, 2023, the time in which the United States is required to file a civil complaint for forfeiture
19 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
20 subject to forfeiture.
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15.

By Stipulation and Order filed October 5, 2023, the parties stipulated to extend to

22 November 6, 2023, the time in which the United States is required to file a civil complaint for forfeiture
23 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
24 subject to forfeiture.
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16.

By Stipulation and Order filed November 3, 2023, the parties stipulated to extend to

26 December 6, 2023, the time in which the United States is required to file a civil complaint for forfeiture
27 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
28 subject to forfeiture.
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Stipulation and Order to Extend Time

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17.

By Stipulation and Order filed December 4, 2023, the parties stipulated to extend to

2 January 5, 2024, the time in which the United States is required to file a civil complaint for forfeiture
3 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
4 subject to forfeiture.
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18.

By Stipulation and Order filed December 29, 2023, the parties stipulated to extend to

6 March 5, 2024, the time in which the United States is required to file a civil complaint for forfeiture
7 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
8 subject to forfeiture.
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19.

By Stipulation and Order filed March 6, 2024, the parties stipulated to extend to April 4,

10 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
11 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
12 forfeiture.
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20.

By Stipulation and Order filed April 4, 2024, the parties stipulated to extend to May 3,

14 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
15 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
16 forfeiture.
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21.

By Stipulation and Order filed May 6, 2024, the parties stipulated to extend to May 31,

18 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
19 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
20 forfeiture.
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22.

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

22 to June 28, 2024, the time in which the United States is required to file a civil complaint for forfeiture
23 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
24 subject to forfeiture.
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Stipulation and Order to Extend Time

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23.

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/or to obtain an indictment
3 alleging that the defendant currency is subject to forfeiture shall be extended to June 28, 2024.
4 Dated: 5/30/24

PHILLIP A. TALBERT
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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8 Dated: 5/30/24
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/s/ Jakrun Sodhi
JAKRUN SODHI
Attorney for potential claimant
Mario Naranjo Gonzalez
(Signature authorized by email)

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IT IS SO ORDERED.

13 Dated: June 3, 2024
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Stipulation and Order to Extend Time