USA v. Approx. $6,700.00 in U.S. Currency

Filing 6

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 05/31/2024 EXTENDING the deadline for the United States 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 to 09/06/2024. (Nair, C)

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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.
APPROXIMATELY $6,700.00 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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2:24-MC-00012-DJC-AC

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

18 Paiz (“claimant”), by and through their respective counsel, as follows:
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1.

On or about October 16, 2023, claimant filed a claim in the administrative forfeiture

20 proceeding with the U.S. Postal Inspection Service with respect to the Approximately $6,700.00 in U.S.
21 Currency (hereafter “defendant currency”), which was seized on August 2, 2023.
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2.

The U.S. Postal Inspection Service has sent the written notice of intent to forfeit required

23 by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a
24 claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than claimant
25 has filed a claim to the defendant currency as required by law in the administrative 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

27 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
28 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
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Stipulation and Order to Extend Time

1 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
2 parties. That deadline was January 12, 2024.
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4.

By Stipulation and Order filed on January 11, 2024, the parties stipulated to extend to

4 March 12, 2024, the time in which the United States is required to file a civil complaint for forfeiture
5 against the defendant funds and/or to obtain an indictment alleging that the defendant currency is subject
6 to forfeiture.
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5.

By Stipulation and Order filed on March 5, 2024, the parties stipulated to extend to June

8 10, 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
9 defendant funds and/or to obtain an indictment alleging that the defendant currency is subject to
10 forfeiture.
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6.

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

12 to September 6, 2024, the time in which the United States is required to file a civil complaint for
13 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
14 currency is subject to forfeiture.
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7.

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

16 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
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Stipulation and Order to Extend Time

1 alleging that the defendant currency is subject to forfeiture shall be extended to September 6, 2024.
2 Dated: 5/31/2024
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PHILLIP A. TALBERT
United States Attorney
By:

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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
/s/ Jacek W. Lentz
JACEK W. LENTZ
Attorney for potential claimant
Daniel Paiz
(Signature authorized by email)

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IT IS SO ORDERED.

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Dated: May 31, 2024

/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE

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Stipulation and Order to Extend Time