USA v. Approximately $33,270.00 in U.S. Currency

Filing 12

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 07/03/2024 EXTENDING the Time to File a Complaint for Forfeiture and/or Obtain an Indictment Alleging Forfeiture to 07/26/2024. (Lopez, K)

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1 2 3 4 PHILLIP A. TALBERT United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 5 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 $33,270.00 IN U.S. CURRENCY, 2:23-MC-00367-KJM-CKD STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE Defendant. 16 17 18 It is hereby stipulated by and between the United States of America and potential claimant Ricky 19 Bill Humbert (“claimant”), by and through their respective counsel, as follows: 20 1. On or about July 18, 2023, claimant Ricky Bill Humbert filed a claim in the administrative 21 forfeiture proceeding with the Drug Enforcement Administration with respect to the Approximately 22 $33,270.00 in U.S. Currency (hereafter “defendant currency”), which was seized on May 3, 2023. The 23 DEA also received an administrative claim from Adriana Jones, but that claim was withdrawn on 24 April 23, 2024, and therefore Andriana Jones is no longer a party to this matter. 25 2. The Drug Enforcement Administration has sent the written notice of intent to forfeit 26 required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any 27 person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other 28 ///// 1 Stipulation and Order to Extend Time 1 than claimant has filed a claim to the defendant currency as required by law in the administrative 2 forfeiture proceeding. 3 3. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for 4 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 proceeding, unless the court extends the deadline for good cause shown or by agreement of the 7 parties. That deadline was October 16, 2023. 8 4. By Stipulation and Order filed October 20, 2023, the parties stipulated to extend to 9 December 15, 2023, the time in which the United States is required to file a civil complaint for forfeiture 10 against the currency and/or to obtain an indictment alleging that the defendant currency is subject to 11 forfeiture. 12 5. By Stipulation and Order filed December 18, 2023, the parties stipulated to extend to 13 February 29, 2024, the time in which the United States is required to file a civil complaint for forfeiture 14 against the currency and/or to obtain an indictment alleging that the defendant currency is subject to 15 forfeiture. 16 6. By Stipulation and Order filed February 28, 2024, the parties stipulated to extend to 17 April 29, 2024, the time in which the United States is required to file a civil complaint for forfeiture 18 against the currency and/or to obtain an indictment alleging that the defendant currency is subject to 19 forfeiture. 20 7. By Stipulation and Order filed April 30, 2024, the parties stipulated to extend to 21 May 29, 2024, the time in which the United States is required to file a civil complaint for forfeiture 22 against the currency and/or to obtain an indictment alleging that the defendant currency is subject to 23 forfeiture. 24 8. By Stipulation and Order filed May 31, 2024, the parties stipulated to extend to 25 June 28, 2024, the time in which the United States is required to file a civil complaint for forfeiture 26 against the currency and/or to obtain an indictment alleging that the defendant currency is subject to 27 forfeiture. 28 ///// 2 Stipulation and Order to Extend Time 1 9. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to further extend 2 to July 26, 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 10. Accordingly, the parties agree that the deadline by which the United States shall be 6 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment 7 alleging that the defendant currency is subject to forfeiture shall be extended to July 26, 2024. 8 Dated: 6/27/2024 9 By: 10 11 12 Dated: 6/24/2024 13 14 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney /s/ Isaac Safier ISAAC SAFIER Attorney for potential claimant Ricky Bill Humbert (Signature authorized by email) 15 ORDER 16 17 PHILLIP A. TALBERT United States Attorney The stipulated request for an extension of time is granted. The deadline by which the United 18 States is required to file a complaint for forfeiture against the defendant currency and/or to obtain an 19 indictment alleging that the defendant currency is subject to forfeiture is extended to July 26, 2024. The 20 court does not anticipate granting any further extensions absent a detailed showing of good cause. 21 IT IS SO ORDERED. 22 DATED: July 3, 2024. 23 24 25 26 27 28 3 Stipulation and Order to Extend Time

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