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United States v. Approximately $20
United States District Court, E.D. California
July 21, 2016
UNITED STATES OF AMERICA, Plaintiff,
APPROXIMATELY $20, 150.00 IN U.S. CURRENCY, Defendant.
PHILLIP A. TALBERT Assistant United States Attorney KEVIN C.
KHASIGIAN Assistant U.S. Attorney Attorneys for the United
CONSENT JUDGMENT OF FORFEITURE
L. Nunley United States District Judge
to the Stipulation for Consent Judgment of Forfeiture, the
1. On February 9, 2016, agents with the United States Postal
Inspection Service (“USPIS”) seized approximately
$20, 150.00 in U.S. Currency (“the defendant
currency”) from Mei during a parcel interdiction at the
Processing and Distribution Center located in West
2. USPIS commenced administrative forfeiture proceedings,
sending direct written notice to all known potential
claimants and publishing notice to all others. On or about
March 28, 2016, USPIS received a claim from Mei asserting an
ownership interest in the defendant currency.
3. The United States represents that it could show at a
forfeiture trial that on February 9, 2016, USPIS conducted a
parcel interdiction at the Processing and Distribution Center
located at 3775 Industrial Boulevard, West Sacramento,
California. During the interdiction, law enforcement
officials identified a parcel that bore markers consistent
with parcels used for shipping contraband. The package was
addressed to Zhong Sheng Li (“Li”), 5663
71st Street, Sacramento, California, 95824-2109,
with the following return address: Chris Mei, 255 West
24th Street, Chicago, Illinois 60617.
4. The United States represents that it could further show at
a forfeiture trial that law enforcement officials contacted
Mei, who confirmed he had sent a package containing cash to
Li. Law enforcement officials contacted Li, who said he was
expecting a “Chinese New Year” gift from Mei. Li
gave consent to open the parcel. The parcel was presented to
a drug detection dog, who positively alerted to the presence
of the odor of narcotics. Upon opening the parcel, law
enforcement agents discovered a plastic shopping bag
containing a text book and multiple dryer sheets inside a
vacuum sealed bag. Concealed within the text book’s
pages were 201 $100 bills and 1 $50 bill; the defendant
5. The United States could further show at a forfeiture trial
that the defendant currency is forfeitable to the United
States pursuant to 21 U.S.C. § 881(a)(6).
6. Without admitting the truth of the factual assertions
contained in this stipulation, claimant specifically denying
the same, and for the purpose of reaching an amicable
resolution and compromise of this matter, claimant agrees
that an adequate factual basis exists to support forfeiture
of the defendant currency. Chris Mei hereby acknowledges that
he is the sole owner of the defendant currency, and that no
other person or entity has any legitimate claim of interest
therein. Should any person or entity institute any kind of
claim or action against the government with regard to its
forfeiture of the defendant currency, claimant shall hold
harmless and indemnify the United States, as set forth below.
7. This Court has jurisdiction in this matter pursuant to 28
U.S.C. §§ 1345 and 1355, as this is the judicial
district in which acts or omissions giving rise to the
8. This Court has venue pursuant to 28 U.S.C. § 1395, as
this is the judicial district in which the defendant currency
9. The parties herein desire to settle this matter pursuant
to the terms of a duly executed Stipulation for Consent
Judgment of Forfeiture.
upon the above findings, and the files and records of the
Court, it is hereby ORDERED
1. The Court adopts the Stipulation for Consent Judgment of
Forfeiture entered into by and ...
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