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United States v. Approximately $18

May 22, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
APPROXIMATELY $18,220.00 IN U.S. CURRENCY, DEFENDANT.



The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

JOINT STATUS REPORT, REQUEST FOR STAY AND PROPOSED ORDER

Plaintiff, United States of America, by and through its undersigned attorney, and claimant herein Manh Saechao, by and through her attorney, Danny D. Brace, Jr., (collectively, the "Parties") submit the following Joint Status Report, Request for Stay and Proposed Order pursuant to the Order Setting Status (Pretrial Scheduling) Conference filed by the Court in this action on February 13, 2009.

a) Status of service of process on parties not yet served:

All known potential claimants have been served with the Complaint for Forfeiture In Rem, Notice of Complaint, Application and Order for Publication, and Court Notices. Accordingly, service is complete. On March 15, 2009, Manh Saechao ("Claimant" or "Saechao") filed a Claim to the defendant property and an Answer to the Complaint for Forfeiture In Rem. On March 26, 2009, the clerk's entry of default was filed as to Juan Gabriel Alvarez and Victor Alvarez. On May 6, 2009, Saechao filed an Amended Claim.

In addition, notice of the forfeiture was published for 30 consecutive days on the official government Internet site (www.forfeiture.gov) commencing on January 26, 2009, in accordance with the Court's Order for Publication, as filed on January 23, 2009. Proof of Publication has been filed with the Court.

b) Possible joinder of additional parties:

None anticipated at this time.

c) Anticipated amendment of pleadings:

None anticipated at this time.

d) The basis for jurisdiction and venue:

The Court has jurisdiction in this matter pursuant to 28 U.S.C. § 1345 and 28 U.S.C. §1355. Venue is proper in this district pursuant to 28 U.S.C. § 1355(b), 28 U.S.C. § 1395(b), and 21 U.S.C. § 881(j).

e) Anticipated motions with suggested dates:

The United States intends to propound special interrogatories pursuant to Supplemental Rule G of the Federal Rules of Civil Procedure ("Supplemental Rule G"). Under Supplemental Rule G(6), the government may serve special interrogatories limited to the claimant's identity and relationship to the defendant property without the court's leave at any ...


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