United States District Court, E.D. California
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
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