United States District Court, C.D. California, Western Division
T. HANNA United States Attorney BRANDON D. FOX Assistant
United states Attorney Chief, Criminal Division STEVEN R.
WELK Assistant United States Attorney Chief, Asset Forfeiture
A. RODGERS Assistant United States Attorney Attorneys for
Plaintiff UNITED STATES OF AMERICA
[PROPOSED] CONSENT JUDGMENT
GARY KLAUSNER UNITED STATES DISTRICT JUDGE
to the stipulation and request of Plaintiff United States of
America and claimant Jaime Rivera (“Claimant”),
the Court hereby enters this Consent Judgment of Forfeiture
containing the terms set forth below:
about February 22, 2019, Plaintiff United States of America
(“the United States of America”) filed a
Complaint for Forfeiture alleging that the defendant
$646,340.00 in U.S. Currency (the “defendant
currency”) is subject to forfeiture pursuant to 21
U.S.C. § 881(a)(6) and 18 U.S.C. § 981(a)(1)(C).
filed a claim to the defendant currency on or about April 10,
2019 and an answer to the complaint on or about April 30,
other parties have appeared in this case and the time for
filing claims and answers has expired.
government and Claimant have now agreed to settle this action
and to avoid further litigation by entering into this Consent
Judgment of Forfeiture.
Court, having been duly advised of and having considered the
matter, and based upon the mutual consent of the parties
hereto, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED:
Court has jurisdiction over the subject matter of this action
and the parties to this Consent Judgment of Forfeiture.
Complaint for Forfeiture states a claim for relief pursuant
to 21 U.S.C. § 881(a)(6) and 18 U.S.C. §
Notice of this action has been given as required by law. No
appearances have been made in the litigation by any person
other than Claimant. The Court deems that all other potential
claimants admit the allegations of the Complaint for
Forfeiture to be true.
United States of America shall have judgment as to the
interests of Claimant and all other potential claimants as to
$621,340.00 of the defendant currency, together with any
interest earned on the defendant currency by the United
States of America since seizure, which funds are hereby
condemned and forfeited to the United States of America. The
United States of America shall dispose of those funds in
accordance with law.
remaining $25,000.00 of the defendant currency, without
interest, shall be returned to Claimant. The funds to be
returned to Claimant shall be paid to Claimant by electronic
transfer directly into the client trust account of the
attorney of record for Claimant in this case. Claimant
(through Claimant’s attorney of record) shall provide
all information and complete all documents requested by the
United States of America in order for the United States of
America to complete the transfer including, without
limitation, providing Claimant’s social security and
taxpayer identification numbers (if any), and the identity of
the bank, the ...