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

Filing 8

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/17/2023 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 2/16/2023. (Donati, J)

Case 2:22-mc-00225-WBS-JDP Document 8 Filed 01/17/23 Page 1 of 3

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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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Case 2:22-mc-00225-WBS-JDP Document 8 Filed 01/17/23 Page 2 of 3

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.

3.

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

4 for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
5 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
6 forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the
7 parties. Those deadlines were July 22, 2022 and August 24, 2022.
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4.

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

9 20, 2022, the time in which the United States is required to file a civil complaint for forfeiture against the
10 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
11 forfeiture.
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5.

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

13 November 18, 2022, the time in which the United States is required to file a civil complaint for forfeiture
14 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
15 subject to forfeiture.
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6.

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

17 January 17, 2023, the time in which the United States is required to file a civil complaint for forfeiture
18 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
19 subject to forfeiture.
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7.

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

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

Case 2:22-mc-00225-WBS-JDP Document 8 Filed 01/17/23 Page 3 of 3

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8.

Accordingly, the parties agree 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 shall be extended to February 16, 2023.

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Dated: 1/17/23

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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9 Dated:

1/13/23

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/s/ Jakrun Sodhi
JAKRUN SODHI
Attorney for potential claimant
Mario Naranjo Gonzalez
Sodhi Law Group
1301 K Street, Suite F
Modesto, CA 95354
209-985-4203
[e-mail]
(Signature authorized by email)

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IT IS SO ORDERED.
Dated: January 17, 2023

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Stipulation and Order to Extend Time