Opinion
2:12-MC-00103-LKK-KJN
03-06-2013
UNITED STATES OF AMERICA, Plaintiff, v. 2011 LAND ROVER RANGE ROVER, VIN: SALSH2E40BA285068, CALIFORNIA LICENSE NUMBER: 6JXN583, Defendant.
BENJAMIN B. WAGNER United States Attorney KEVIN C. KHASIGIAN Assistant U. S. Attorney Attorneys for the United States DAVID WEINER Attorney for claimant Troy David Stratos (Signature retained by attorney)
BENJAMIN B. WAGNER
United States Attorney
KEVIN C. KHASIGIAN
Assistant U. S. Attorney
Attorneys for the United States
STIPULATION AND ORDER
EXTENDING TIME FOR FILING
A COMPLAINT FOR
FORFEITURE AND/OR TO
OBTAIN AN INDICTMENT
ALLEGING FORFEITURE
It is hereby stipulated by and between the United States of America and claimant Troy David Stratos ("claimant"), by and through their respective counsel, as follows:
1. On or about September 12, 2012, claimant Troy David Stratos filed a claim, in the administrative forfeiture proceedings, with the Federal Bureau of Investigation with respect to the 2011 Land Rover Range Rover, VIN: SALSH2E40BA285068, California License Number: 6JXN583 (hereafter "defendant vehicle"), which was seized on June 21, 2012.
2. The Federal Bureau of Investigation 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 vehicle under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the defendant vehicle 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 vehicle and/or to obtain an indictment alleging that the defendant vehicle 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 11, 2012.
4. By Stipulation and Order filed December 5, 2012, the parties stipulated to extend to March 11, 2013, the time in which the United States is required to file a civil complaint for forfeiture against the defendant vehicle and/or to obtain an indictment alleging that the defendant vehicle is subject to forfeiture.
5. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement for an extension to June 10, 2013, the time in which the United States is required to file a civil complaint for forfeiture against the defendant vehicle and/or to obtain an indictment alleging that the defendant vehicle is subject to forfeiture.
6. Accordingly, the parties agree that the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant vehicle and/or to obtain an indictment alleging that the defendant vehicle is subject to forfeiture shall be extended to June 10, 2013.
BENJAMIN B. WAGNER
United States Attorney
By: ______________________
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
________________________
DAVID WEINER
Attorney for claimant
Troy David Stratos
(Signature retained by attorney)
IT IS SO ORDERED.
________________________
LAWRENCE K. KARLTON
SENIOR JUDGE
UNITED STATES DISTRICT COURT