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)

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
[phone]
[e-mail]
(P-53291)

S/TODD FLOOD (with consent)
Todd Flood, Esq.
Attorney for Claimant
401 North Main Street
Royal Oak, MI 48067
[phone]
[e-mail]
(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

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