United States v. Approximately $30

          United States of America, Plaintiff, represented by Kevin Christopher Khasigian, United States Attorney's Office.

          Juber Flores-Suarez, Claimant, represented by Brett A. Purtzer, Hester Law Group, pro hac vice & Daniel S. Stouder, Boutin Jones Inc..

          Rafael Martinez-Suarez, Claimant, represented by Brett A. Purtzer, Hester Law Group, pro hac vice & Daniel S. Stouder, Boutin Jones Inc..

          STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE

          TROY L. NUNLEY, District Judge.

         It is hereby stipulated by and between the United States of America and claimants Juber Flores-Suarez ("claimants" or "Flores-Suarez") and Rafael Martinez-Suarez ("claimants" or "Martinez-Suarez"), by and through their respective counsel, as follows:

         1. On or about September 29, 2014, claimants Juber Flores-Suarez and Rafael Martinez-Suarez filed claims, in the administrative forfeiture proceedings, with the Drug Enforcement Administration with respect to the Approximately $30, 000.00 in U.S. Currency (hereafter "defendant currency"), which was seized on June 9, 2014.

         2. The Drug Enforcement Administration has sent the written notice of intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the defendant currency as required by law in the administrative forfeiture proceeding.

         3. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture within ninety 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. That deadline was December 26, 2014.

         4. By Stipulation and Order filed December 24, 2014, the parties stipulated to extend to February 24, 2015, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

         5. By Stipulation and Order filed February 23, 2015, the parties stipulated to extend to April 25, 2015, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

         6. By Stipulation and Order filed April 20, 2015, the parties stipulated to extend to June 24, 2015, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

         7. By Stipulation and Order filed June 26, 2015, the parties stipulated to extend to September 22, 2015, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

         8. By Stipulation and Order filed September 21, 2015, the parties stipulated to extend to November 20, 2015, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

         9. By Stipulation and Order filed November 20, 2015, the parties stipulated to extend to January 19, 2016, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an ...