United States of America v. Approximately $139,740 In United States Currency

Filing 8

STIPULATION AND ORDER to continue date to file answer to complaint. Signed by Judge Thelton E. Henderson on 02/16/10. (rbe, COURT STAFF) (Filed on 2/17/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RANDY SUE POLLOCK Attorney at Law (CSBN 64473) 2831 Telegraph Avenue Oakland, CA 94609 San Francisco, CA 94109 Telephone: (510) 763-9967 Facsimile: (510) 272-0711 Attorney for Defendant NONI ALEXANDER UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ­ooo­ UNITED STATES OF AMERICA, Plaintiff, vs. APPROXIMATELY $139,740 IN UNITED STATES CURRENCY, Defendant / Claimant Noni Alexander, by and through her counsel of record Randy Sue Pollock, and Claimant Brandon Johnson, by and through his counsel of record Jai Gohel, and Assistant United States Attorney David Countryman, hereby jointly agree to continue the date on which an answer must be filed to the government's complaint for forfeiture to July 30, 1010. Claimant Johnson presently has federal criminal charges pending in Philadelphia, PA [CR. 09-00535-JCJ] and a trial date of June 28, 2010. STIPULATION TO CONTINUE DATE TO FILE ANSWER TO COMPLAINT FOR FORFEITURE ___________________________ C-10-0186-TEH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Claimants Johnson and Alexander jointly have criminal charges pending in Alameda County Superior Court [Case No. 553400A]. The currency at issue in this forfeiture was seized during the arrest in the Alameda County case. This case is trailing the federal criminal case in Pennsylvania. The parties do not anticipate a resolution of this forfeiture case until both criminal cases are resolved. Date: February 15, 2010 /s/ Randy Sue Pollock Counsel for Claimant Noni Alexander /s/ Jai Gohel Counsel for Claimant Brandon Johnson /s/ David Countryman Assistant U.S. Attorney Date: February 15, 2010 Date: February 15, 2010 SO ORDERED: Date: February 16 ,2010 UNIT ED S DISTRICT TE C TA THELTON E. HENDERSON U.S. District Court Judge RT U O S Ju d ER N F D IS T IC T O R 2 A C LI FO ton E. H ge Thel enderso n R NIA NO RT H

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