United States of America v. Currency $19,315.18 From Bank of America Account #237033591854

Filing 8

STIPULATION AND ORDER STAYING CASE For 90 Days Signed by District Judge Victoria A. Roberts. (CPin)

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
United States of America,
Plaintiff,
vs.

Case No. 18-cv-11307
Honorable: Victoria A. Roberts

Nineteen Thousand Three Hundred
Fifteen Dollars and Eighteen Cents
($19,315.18) in U.S. Currency
from Bank of America Account
Number: 237033591854
Defendant In Rem.
___________________________________________/
STIPULATION FOR ENTRY OF ORDER STAYING
PROCEEDING FOR A PERIOD OF 90 DAYS
NOW COMES the Plaintiff, the United States of America, by and through
Matthew Schneider, United States Attorney, and Philip A. Ross, Assistant United
States Attorney, and Claimant, E.L. Mann, Inc., by and through its attorney, John
D. Dakmak, Esq., hereby acknowledge that there is an ongoing criminal
investigation related to the above-captioned civil forfeiture case, and stipulate as
follows:
IT IS HEREBY STIPULATED AND AGREED that this civil forfeiture
case be stayed for a period of 90 days 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; that the stay continue during the pendency of the investigation and
criminal proceedings, if any, 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 the parties shall
have a reasonable time to conduct discovery, file dispositive motions, and file all
witness lists 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 scheduling conference.
Approved as to substance and form:
Respectfully submitted,
Matthew Schneider
United States Attorney
s/Philip A. Ross
Philip A. Ross
Assistant United States Attorney
211 W. Fort Street, Ste. 2001
Detroit, MI 48226
Phone: [phone]
e-mail: [e-mail]
Va. State Bar #70269

s/John D. Dakmak (with consent)
John D. Dakmak
Counsel for Claimant
500 Woodward Ave., Ste. 3500
Detroit, MI 48226
Phone: [phone]
e-mail: [e-mail]
(P58210)

Dated: June 14, 2018

Dated: June 14, 2018

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IT IS SO ORDERED:

S/Victoria A. Roberts
Victoria A. Roberts
United States District Judge
Dated: June 15, 2018

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