USA v. Approx. $282,500.00 in U.S. Currency

Filing 10

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 3/10/2025 ORDERING that the deadline by which the United States shall be required 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 shall be EXTENDED to 4/24/2025. (Deputy Clerk LMS)

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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: [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,

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v.
APPROXIMATELY $282,500.00 IN
U.S. CURRENCY,

2:24-MC-00317-DJC-CKD
STIPULATION AND ORDER EXTENDING
TIME FOR FILING A COMPLAINT FOR
FORFEITURE AND/OR TO OBTAIN AN
INDICTMENT ALLEGING FORFEITURE

Defendant.

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

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

On or about May 15, 2024, claimant filed a claim in the administrative forfeiture

21 proceeding with the Drug Enforcement Administration with respect to the above-referenced currency
22 (hereafter “defendant currency”), which was seized on or about February 9, 2024.
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2.

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

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

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3.

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

2 forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant
3 currency is subject to forfeiture within ninety days after a claim has been filed in the administrative
4 forfeiture proceeding, unless the court extends the deadline for good cause shown or by agreement of the
5 parties. That deadline was August 13, 2024.
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4.

By Stipulation and Order filed August 13, 2024, the parties stipulated to extend to October

7 11, 2024, the time in which the United States is required to file a civil complaint for forfeiture against the
8 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to
9 forfeiture.
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5.

By Stipulation and Order filed October 8, 2024, the parties stipulated to extend to

11 December 10, 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 December 9, 2024, the parties stipulated to extend to

15 February 7, 2025, the time in which the United States is required to file a civil complaint for forfeiture
16 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
17 subject to forfeiture.
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7.

By Stipulation and Order filed February 6, 2025, the parties stipulated to extend to March

19 10, 2025, 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.

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

23 to April 24, 2025, the time in which the United States is required to file a civil complaint for forfeiture
24 against the defendant currency and/or to obtain an indictment alleging that the defendant currency is
25 subject to forfeiture.
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Stipulation and Order to Extend Time

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9.

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

2 required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment
3 alleging that the defendant currency is subject to forfeiture shall be extended to April 24, 2025.
4 Dated: 3/7/2025
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MICHELE BECKWITH
Acting United States Attorney
By:

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8 Dated: 3/7/2025
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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
/s/ Isaac Safier
ISAAC SAFIER
Attorney for potential claimant
Ronnie Borrego
(Authorized by email)

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IT IS SO ORDERED.

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

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Stipulation and Order to Extend Time