United States of America v. Currency $8,526.53 From Comerica Bank Account #1852550712 et al

Filing 11

STIPULATION AND ORDER STAYING civil forfeiture proceeding. Status report due 6/9/16. Signed by District Judge George Caram Steeh. (MBea)

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, Civil No. 15-13631 Honorable: George Caram Steeh vs. EIGHT THOUSAND FIVE HUNDRED TWENTY-SIX DOLLARS AND FIFTY-THREE CENTS ($8,526.53) IN U.S. CURRENCY FROM COMERICA BANK ACCOUNT #1852550712; AND ONE (1) 2011 MERCEDES-BENZ, GL 450, VIN: 4JGBF7BE7BA688242, Defendants In Rem. ________________________________________/ STIPULATION FOR ENTRY OF ORDER STAYING CIVIL FORFEITURE PROCEEDING Plaintiff, the United States of America, and Claimant, Mark Sitto, by and through their undersigned attorneys, hereby acknowledge that there is an ongoing criminal investigation involving Claimant that is related to this civil forfeiture case. Therefore: IT IS HEREBY STIPULATED AND AGREED that this civil forfeiture case be stayed pursuant to 18 U.S.C. '981(g)(1), or alternatively, 18 U.S.C. '981(g)(2), on the grounds that continuation of the civil proceeding may negatively impact one or all parties in the manner described in the cited statutes. The parties agree that the stay continue during the pendency of the investigation and related criminal proceedings, or until further order of the Court without prejudice to any of the parties to seek an advance termination or an extension of the stay. IT IS FURTHER STIPULATED AND AGREED that upon termination of the stay, both parties shall be afforded a reasonable time to file witness lists, conduct discovery, and file dispositive motions prior to any pretrial or trial proceedings. No claims or defenses are waived as a result of the stay. IT IS FURTHER STIPULATED AND AGREED that upon termination of the stay, the Court will set a new scheduling conference to take place. The parties shall give the court a status report in six months (on or before June 9, 2016). Respectfully submitted, BARBARA L. McQUADE United States Attorney S/JULIE A. BECK Assistant United States Attorney 211 W. Fort Street, Suite 2001 Detroit, MI 48226 (313) 226-9717 julie.beck@usdoj.gov (P-53291) S/TODD FLOOD (with consent) Todd Flood, Esq. Attorney for Claimant 401 North Main Street Royal Oak, MI 48067 (248) 547-1032 tflood@floodlaw.com (P-58555) Dated: December 9, 2015 Dated: December 9, 2015 ***************************************************************************** IT IS SO ORDERED: s/George Caram Steeh HONORABLE GEORGE CARAM STEEH United States District Judge Dated: December 9, 2015 2

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