USA v. Approx. $269,565.50

Filing 7

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 1/3/2025 EXTENDING Time for filing a Complaint to 4/2/2025. (Deputy Clerk VLK)

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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,

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2:24-MC-00402-DJC-SCR

v.
APPROXIMATELY $269,565.50 SEIZED FROM
FIRST RELIANCE BANCSHARES, INC.
ACCOUNT NUMBER 5220000969, HELD IN THE
NAME OF LIFESTYLE DEVELOPMENT, LLC,

AMENDED STIPULATION AND ORDER
EXTENDING TIME FOR FILING A
COMPLAINT FOR FORFEITURE AND/OR
TO OBTAIN AN INDICTMENT ALLEGING
FORFEITURE

APPROXIMATELY $1,373.95 SEIZED FROM
VALLEY NATIONAL BANK ACCOUNT
NUMBER 8843534202, HELD IN THE NAME OF
LIFESTYLE DEVELOPMENT, LLC,
APPROXIMATELY $7,982.56 SEIZED FROM
FIRST RELIANCE BANCSHARES, INC.
ACCOUNT NUMBER 5210000745, HELD IN THE
NAME OF THOMAS EIDE,
APPROXIMATELY $50,000.00 SEIZED FROM
MAINSTREET BANK ACCOUNT NUMBER
2010039009, HELD IN THE NAME OF PRV
INTERNATIONAL, LLC,
APPROXIMATELY $36,650.38 SEIZED FROM
BANK OF AMERICA, N.A. ACCOUNT NUMBER
383019458700, HELD IN THE NAME OF
VITAKEM NUTRA, AND

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Amended Stipulation and Order to Extend Time

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APPROXIMATELY $37,886.31 SEIZED FROM
SOUTHSTATE BANK, NA ACCOUNT NUMBER
8010002012630, HELD IN THE NAME OF
SARAH NICK,

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Defendants.

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

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7 Thomas Eide on behalf of himself and Lifestyle Development, LLC, by and through their respective
8 counsel, Erick Reyes-Villa as representative for PRV International, LLC, and Bret Hoyt as representative
9 for Vitakem Nutraceutical, Inc. (“claimants”), as follows:
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On or about May 7, 2024, the U.S. Postal Inspection Service (“USPIS”) seized the above-

11 referenced defendant funds1 pursuant to Federal seizure warrants (hereafter collectively “defendant
12 funds”).
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Under 18 U.S.C. §§ 983(a)(1)(A)(i)-(iv), and 983(a)(3)(A), the United States is required to

14 send notice to potential claimants, file a complaint for forfeiture against the defendant funds, or obtain an
15 indictment alleging that the defendant funds are subject to forfeiture within one hundred and fifty days of
16 seizure, unless the court extends the deadline for good cause shown or by agreement of the parties. That
17 deadline was October 4, 2024.
3.

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By Stipulation and Order filed October 9, 2024, the parties stipulated to extend to January

19 2, 2025, the time in which the United States is required to file a civil complaint for forfeiture against the
20 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
4.

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

22 2, 2025, the time in which the United States is required to file a civil complaint for forfeiture against the
23 defendant funds and/or to obtain an indictment alleging that the defendant funds are subject to forfeiture.
5.

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

25 required to file a complaint for forfeiture against the defendant funds and/or to obtain an indictment
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The United States is no longer seeking forfeiture of the Approximately $37,886.31 seized from Southstate Bank, NA account

28 number 8010002012630, held in the name of Sarah Nick.

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Amended Stipulation and Order to Extend Time

1 alleging that the defendant funds are subject to forfeiture shall be extended to April 2, 2025.
2 Dated: 12/30/2024
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PHILLIP A. TALBERT
United States Attorney
By:

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6 Dated: 12/30/2024
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10 Dated: 1/2/2025
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15 Dated: 12/30/2024
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/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
/s/ Daniel Olmos
DANIEL OLMOS
Attorney for potential claimant Thomas Eide on
behalf of himself and Lifestyle Development, LLC
600 University Avenue
Palo Alto, CA 94301
(Signature authorized by email)
/s/ Erick Reyes-Villa
ERICK REYES-VILLA
Potential Claimant on behalf of
PRV International, LLC
Appearing in propria persona
1055 Thomas Jefferson Street NW, Suite 620
Washington, DC 20007
(Signature authorized by email)
/s/ Bret Hoyt
BRET HOYT
Potential Claimant on behalf of
Vitakem Neutraceuticals, Inc.
Appearing in propria persona
811 W. Jericho Turnpike
Smithtown, NY 11787
(Signature authorized by email)

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IT IS SO ORDERED.

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23 Dated: January 3, 2025

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

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Amended Stipulation and Order to Extend Time