United States of America v. 2021 Toyota TRD 4Runner, VIN: JTEPU5JR4M5948693 et al

Filing 2

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 9/21/2023 EXTENDING time for the United States to file a complaint for forfeiture against the Defendant vehicles or to obtain an indictment alleging that the defendant vehicles are subject to forfeiture, by 11/21/23. (Clemente Licea, O)

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PHILLIP A. TALBERT
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. 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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Plaintiff,
v.
2021 TOYOTA TRD 4RUNNER,
VIN: JTEPU5JR4M5948693, LICENSE
NUMBER: 8XXF463 and

2:23-MC-00350-DJC-DB
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

2022 MERCEDES BENZ AMG CLA 4MATIC,
VIN: W1K3G4EB0NJ364663, LICENSE
NUMBER: 9BYD950,

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Defendants.

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

21 Michael W. Bowden, Kasandra Dolan, and Michael J. Bowden (“claimants”), by and through their
22 respective counsel, as follows:
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1.

On or about June 26, 2023, claimants Michael W. Bowden, Kasandra Dolan, and Michael

24 J. Bowden filed claims in the administrative forfeiture proceeding with the Drug Enforcement
25 Administration with respect to the above-referenced vehicles (hereafter “defendant vehicles”), which
26 were seized on March 23, 2023.
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2.

The Drug Enforcement Administration has sent the written notice of intent to forfeit

28 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any
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Stipulation and Order to Extend Time

1 person to file a claim to the defendant vehicles under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other
2 than claimants has filed a claim to the defendant vehicles as required by law in the administrative
3 forfeiture proceeding.
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3.

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

5 forfeiture against the defendant vehicles and/or to obtain an indictment alleging that the defendant
6 vehicles are subject to forfeiture within ninety days after a claim has been filed in the administrative
7 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
8 parties. That deadline is September 22, 2023.
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4.

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

10 November 21, 2023, the time in which the United States is required to file a civil complaint for forfeiture
11 against the defendant vehicles and/or to obtain an indictment alleging that the defendant vehicles are
12 subject to forfeiture.
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5.

Accordingly, the parties agree that the deadline by which the United States shall be

14 required to file a complaint for forfeiture against the defendant vehicles and/or to obtain an indictment
15 alleging that the defendant vehicles are subject to forfeiture shall be extended to November 21,2023.
16 Dated: 9/20/2023

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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21 Dated: 9/18/2023
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/s/ Candice Fields
CANDICE FIELDS
Attorney for potential claimants Michael J Bowden,
Michael W. Bowden, and Kasandra Dolan
(Authorized by email)

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IT IS SO ORDERED.

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Dated: September 21, 2023

/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
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Stipulation and Order to Extend Time