United States v. Approximately $380

          McGREGOR W. SCOTT United States Attorney MICHELE BECKWITH KEVIN C. KHASIGIAN Assistant U.S. Attorneys Attorneys for the United States

          CONSENT JUDGMENT OF FORFEITURE

          John A. Mendez United States District Court Judge

         Pursuant to the Stipulation for Consent Judgment of Forfeiture, the Court finds:

         1. In October 2013, law enforcement intercepted several parcels containing cash sent from Pennsylvania to a P.O. Box in Fairfield, California controlled by Brian Robinson ("Robinson" or "claimant") and Kimberly Santiago Robinson ("Santiago Robinson" or "claimant"). After a drug dog positively alerted to the odor of narcotics on the packages, law enforcement searched them and found several empty cereal boxes containing approximately $289, 400 in cash. Law enforcement subsequently searched Robinson's and Santiago Robinson's Fairfield home and discovered $20, 000 in cash, a money counter, items consistent with marijuana trafficking, and documents connecting Cue Thi Schaeffer ("Schaeffer" or "claimant") and John Acosta ("Acosta" or "claimant") to marijuana grow properties in California. After the search, law enforcement searched two more packages addressed to Brian Robinson at his P.O. Box in Fairfield, California. The packages contained a total of $164, 020 in cash.

         2. On November 8, 2013, law enforcement searched 3301 Pope Avenue in Sacramento, California, a property identified through documents found at Robinson's Fairfield home. During the search, law enforcement found paperwork linking the occupant, Schaeffer, to Robinson, Acosta and marijuana trafficking, as well as property located at 6300 Blarney Way in Pilot Hill, California. Law enforcement interviewed Schaeffer who acknowledged owning 6300 Blarney Way in Pilot Hill, California, and renting the property to Acosta. Pilot Hill is a rural town located in El Dorado County.

         3. On November 13, 2013, law enforcement searched 6300 Blarney Way in Pilot Hill and found a dismantled marijuana grow operation containing piles of marijuana leaves and trimmings, pots containing marijuana stalks, and marijuana drying devices. An aerial image obtained by law enforcement shows an active marijuana grow at the property on September 13, 2013.

         4. On January 31, 2014, law enforcement arrested Antonio Benitez Gonzalez ("Gonzalez" or "claimant") after connecting his vehicle to marijuana trafficking through a receipt signed by Schaeffer. Gonzalez acknowledged to law enforcement that he assisted Acosta with the marijuana grow operation in El Dorado County (Pilot Hill) and operating an indoor grow operation at a house located at 150 Arcade Boulevard in Salinas, California.

         5. On March 18, 2014, law enforcement searched 150 Arcade Boulevard in Salinas, California and found forty-nine mature marijuana plants, multiple rolls of vacuum-seal plastic and pre-cut squares of vacuum-sealing packaging. Acosta was present at the house during the search.

         6. On or about April 25, 2014, Seward County Sheriffs Officers conducted a traffic stop of Robinson's 2008 GMS Sierra pickup truck as the vehicle traveled westbound on Interstate 80 in Seward County, Nebraska. Robinson was the driver and sole occupant of the vehicle. A drug dog trained to alert to the presence of the odor of narcotics was present at the traffic stop and positively alerted to the odor of narcotics on Robinson's vehicle. A subsequent search of the vehicle uncovered a black duffel bag containing eleven Ziplock bags stuffed with rubber-banded bundles of currency. A later bank count of the rubber-banded cash seized from the duffel bag totaled $380, 050.00 in cash-the "defendant $380, 050.00 in U.S. Currency."

         7. On June 1, 2015, law enforcement searched Robinson's and Santiago Robinson's Fairfield home and found $80, 000 in cash-the "defendant $80, 000.00 in U.S. Currency." Law enforcement also seized bank accounts connected to Robinson, Santiago Robinson and/or Robinson's businesses at the following financial institutions: PNC Bank, Travis Credit Union, Wells Fargo Bank, Edward Jones, and United Services Automobile Association ("USAA"). In total, law enforcement seized ten bank accounts, as set forth above.

         8. Claimants do not dispute the United States could show at a forfeiture trial that the defendant assets are forfeitable to the United States pursuant to 21 U.S.C. § 881(a)(6).

         9. Without admitting the truth of the factual assertions contained above, claimants specifically denying the same, and for the purpose of reaching an amicable resolution and compromise of this matter, claimants agree that an adequate factual basis exists to support forfeiture of the defendant assets. Claimants acknowledged that they are the sole owners of the defendant assets, 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 assets, claimants shall hold harmless and indemnify the United States, as set forth below.

         10. 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 ...