USA v. Approx. $7,464.64 in U.S. Currency
Filing
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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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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
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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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Plaintiff,
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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.
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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:
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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.
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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
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Stipulation and Order to Extend Time
1 parties. That deadline was June 16, 2023.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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Stipulation and Order to Extend Time
1 subject to forfeiture.
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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.
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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.
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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
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By:
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17 Dated: 1/27/2025
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/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)
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MICHELE BECKWITH
Acting United States Attorney
IT IS SO ORDERED.
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23 Dated: January 27, 2025
/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
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Stipulation and Order to Extend Time
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