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

Filing 46

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 10/28/2024 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 to 11/15/24. (Lopez, K)

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4 PHILLIP A. TALBERT 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 2:22-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 15 16 APPROXIMATELY $33,000.00 IN U.S. CURRENCY, 17 Defendants. 18 19 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: 21 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. 24 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. 27 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 1 Stipulation and Order to Extend Time 29 30 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. 4 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. 9 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. 13 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. 17 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. 21 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. 25 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. 29 30 2 Stipulation and Order to Extend Time 1 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. 5 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. 9 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. 13 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. 17 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. 21 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. 25 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. 29 30 3 Stipulation and Order to Extend Time 1 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. 5 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. 9 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. 13 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. 17 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. 21 22. By Stipulation and Order filed June 4, 2024, the parties stipulated to extend to June 28, 22 2024, the time in which the United States is required to file a civil complaint for forfeiture against the 23 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 24 forfeiture. 25 23. By Stipulation and Order filed July 2, 2024, the parties stipulated to extend to July 26, 26 2024, the time in which the United States is required to file a civil complaint for forfeiture against the 27 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 28 forfeiture. 29 30 4 Stipulation and Order to Extend Time 1 24. By Stipulation and Order filed July 23, 2024, the parties stipulated to extend to August 23, 2 2024, 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. 5 25. By Stipulation and Order filed August 23, 2024, the parties stipulated to extend to 6 September 20, 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. 9 26. By Stipulation and Order filed September 23, 2024, the parties stipulated to extend to 10 October 18, 2024, the time in which the United States is required to file a civil complaint for forfeiture 11 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 12 subject to forfeiture. 13 27. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 14 to November 15, 2024, the time in which the United States is required to file a civil complaint for 15 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant 16 currency is subject to forfeiture. 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 29 30 5 Stipulation and Order to Extend Time 1 28. 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 November 15, 2024. 4 Dated: 10/17/24 PHILLIP A. TALBERT United States Attorney 5 By: 6 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U. S. Attorney 7 8 Dated: 10/17/24 9 10 /s/ Jakrun Sodhi JAKRUN SODHI Attorney for potential claimant Mario Naranjo Gonzalez (Signature authorized by email) 11 12 IT IS SO ORDERED. 13 Dated: October 28, 2024 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 6 Stipulation and Order to Extend Time

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