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United States v. Approximately $9

United States District Court, Ninth Circuit

December 10, 2013

UNITED STATES OF AMERICA, Plaintiff,
v.
APPROXIMATELY $9, 224.00 IN U.S. CURRENCY Defendant.

BENJAMIN B. WAGNER, United States Attorney, JEFFREY A. SPIVAK, Assistant United States Attorney, Sacramento, California, Attorneys for United States of America.

DAVID M. DUDLEY, Attorney for Claimant Cristina Ross

STIPULATION AND ORDER EXTENDING THE UNITED STATES' TIME TO FILE A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE

LAWRENCE J. O'NEILL, District Judge.

It is hereby stipulated by and between the United States of America and Claimant Cristina Ross, ("Claimant"), by and through their respective attorneys, as follows:

1. On or about July 11, 2012, Claimant filed a claim with the Internal Revenue Service Criminal Investigations with respect to the above-referenced approximately $9, 224.00 in U.S. Currency (the "currency") which was seized on or about May 11, 2012.

2. The Internal Revenue Service Criminal Investigations has sent written notice of intent to forfeit as required by 18 U.S.C. § 983 to all known interested parties. The time has expired for any person to file a claim to the currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the Claimant has filed a claim to the currency in the administrative forfeiture proceeding.

3. Title 18 U.S.C. § 983(a)(3)(A) requires the United States to file a complaint for forfeiture against the currency and/or to obtain an indictment alleging that the currency is subject to forfeiture within 90 days after a claim has been filed in the administrative forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the parties.

4. By Stipulation and Order filed on October 5, 2012, the parties stipulated to extend to January 7, 2013, the time in which to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture.

5. By Stipulation and Order filed on January 2, 2013 the parties stipulated to extend to April 8, 2013, the time in which to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture.

6. By Stipulation and Order filed on April 5, 2013 the parties stipulated to extend to July 8, 2013, the time in which to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture.

7. By Stipulation and Order filed on June 26, 2013 the parties stipulated to extend to September 30, 2013, the time in which to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture.

8. By Stipulation and Order filed on September 27, 2013, the parties stipulated to extend to December 15, 2013, the time in which to file a Complaint for Forfeiture and/or to Obtain an Indictment Alleging Forfeiture.

9. Since that time, the parties have been in active settlement negotiations. On December 9, 2013, the parties agreed a tentative deal, in principle, to resolve the case. The parties need additional time to finalize the settlement.

10. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to March 14, 2014, the time in which the United States is required to file a civil complaint for forfeiture against the currency and/or to obtain an indictment alleging that the currency is subject to forfeiture.

11. Accordingly, the parties agree that the deadline by which the United States shall be required to file a complaint for forfeiture against the currency and/or to obtain an indictment alleging that the currency is subject to forfeiture shall be extended to March 14, 2014.

IT IS SO ORDERED.


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