USA v. Approx. $7,464.64 in U.S. Currency

Filing 19

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 1/27/2025 EXTENDING the Time for Filing a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture to 3/6/2025. (Deputy Clerk KEZ)

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1 4 MICHELE BECKWITH Acting United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 5 Attorneys for the United States 2 3 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 14 15 v. APPROXIMATELY $7,464.64 IN U.S. CURRENCY, STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE Defendant. 16 17 2:23-MC-00232-DJC-SCR It is hereby stipulated by and between the United States of America and potential claimant Arnes 18 Krajinic (“claimant”), by and through their respective counsel, as follows: 19 1. On or about January 17, 2023, agents with the Placer County Special Investigation Unit 20 seized $7,414.00 in U.S. Currency incident to arrest. On or about June 7, 2023, the Bureau of Alcohol, 21 Tobacco, Firearms, and Explosives seized the Approximately $7,464.64 in U.S. Currency (hereafter 22 “defendant currency”) pursuant to a federal seizure warrant. The seized amount, $7,464.64, represents 23 the $7,414.00 in cash seized from Krajinic plus the accrued interest on the seized amount ($50.64) since 24 the arrest of Krajinic. 25 2. Under 18 U.S.C. §§ 983(a)(1)(A)(i)-(iv), and 983(a)(3)(A), the United States is required to 26 send notice to potential claimants, file a complaint for forfeiture against the defendant currency, or obtain 27 an indictment alleging that the defendant currency is subject to forfeiture within one hundred and fifty 28 days of seizure, unless the court extends the deadline for good cause shown or by agreement of the 1 Stipulation and Order to Extend Time 1 parties. That deadline was June 16, 2023. 2 3. By Stipulation and Order filed June 21, 2023, the parties stipulated to extend to September 3 14, 2023, the time in which the United States is required to file a civil complaint for forfeiture against the 4 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 5 forfeiture. 6 4. By Stipulation and Order filed September 11, 2023, the parties stipulated to extend to 7 November 13, 2023, the time in which the United States is required to file a civil complaint for forfeiture 8 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 9 subject to forfeiture. 10 5. By Stipulation and Order filed November 13, 2023, the parties stipulated to extend to 11 February 12, 2024, the time in which the United States is required to file a civil complaint for forfeiture 12 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 13 subject to forfeiture. 14 6. By Stipulation and Order filed February 8, 2024, the parties stipulated to extend to May 15 13, 2024, the time in which the United States is required to file a civil complaint for forfeiture against the 16 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 17 forfeiture. 18 7. By Stipulation and Order filed May 13, 2024, the parties stipulated to extend to August 9, 19 2024, the time in which the United States is required to file a civil complaint for forfeiture against the 20 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 21 forfeiture. 22 8. By Stipulation and Order filed August 9, 2024, the parties stipulated to extend to October 23 8, 2024, the time in which the United States is required to file a civil complaint for forfeiture against the 24 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to 25 forfeiture. 26 9. By Stipulation and Order filed October 7, 2024, the parties stipulated to extend to 27 December 6, 2024, the time in which the United States is required to file a civil complaint for forfeiture 28 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 2 Stipulation and Order to Extend Time 1 subject to forfeiture. 2 10. By Stipulation and Order filed December 4, 2024, the parties stipulated to extend to 3 February 4, 2025, the time in which the United States is required to file a civil complaint for forfeiture 4 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 5 subject to forfeiture. 6 11. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 7 to March 6, 2025, the time in which the United States is required to file a civil complaint for forfeiture 8 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is 9 subject to forfeiture. 10 12. Accordingly, the parties agree that the deadline by which the United States shall be 11 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 12 alleging that the defendant currency is subject to forfeiture shall be extended to March 6, 2025. 13 Dated: 1/27/2025 14 By: 15 16 17 Dated: 1/27/2025 18 19 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney /s/ David D. Fischer DAVID D. FISCHER Attorney for potential claimant Arnes Krajinic (Signature authorized by email) 20 21 MICHELE BECKWITH Acting United States Attorney IT IS SO ORDERED. 22 23 Dated: January 27, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE 24 25 26 27 28 3 Stipulation and Order to Extend Time

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