United States v. Approximately $28,360.00 in U.S. Currency ( 2021 )

11 PHILLIP A. TALBERT Acting United States Attorney 22 KEVIN C. KHASIGIAN Assistant U.S. Attorney 33 501 I Street, Suite 10-100 Sacramento, CA 95814 44 Telephone: (916) 554-2700 55 Attorneys for the United States 66 77 88 IN THE UNITED STATES DISTRICT COURT 99 EASTERN DISTRICT OF CALIFORNIA 1100 1111 UNITED STATES OF AMERICA, 2:20-CV-02043-WBS-AC 1122 Plaintiff, UNITED STATES’ REQUEST TO 1133 v. EXTEND THE DEADLINE TO SUBMIT A JOINT STATUS REPORT 1144 APPROXIMATELY $28,360.00 IN U.S. FROM APRIL 12, 2021 TO JUNE 14, CURRENCY, 2021 1155 Defendant. 1166 1177 The United States submits the following Request to Extend the Deadline to file a Joint Status 1188 Report from April 12, 2021 to June 14, 2021. 1199 Introduction 2200 On October 13, 2020, the United States filed a civil forfeiture complaint in rem against the 2211 above-captioned currency (“defendant currency”), based on its involvement in federal drug law 2222 violations. All known potential claimants to the defendant currency were served in a manner consistent 2233 with Dusenbery v. United States, 534 U.S. 161, 168 (2002) and the applicable statutory authority. 2244 Additionally, public notice on the official internet government forfeiture site, www.forfeiture.gov, began 2255 on October 23, 2020, and ran for thirty consecutive days, as required by Rule G(4)(a)(iv)(C) of 2266 Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions. A Declaration of 2277 Publication was filed on November 21, 2020. ] Good Cause 2 The United States has provided notice to all potential claimants pursuant to law. Specifically, 3 || the United States served a copy of the complaint documents to potential claimant Christopher Reyes via 4 || certified, first class mail and personal service. To date, no claim or answer has been filed by or on 5 || behalf of Christopher Reyes as required by Rule G(5) of the Supplemental Rules for Admiralty or 6 || Maritime Claims and Asset Forfeiture Actions, and his time to file a claim and answer has expired. 7 Accordingly, the United States filed a Clerk’s Default against Christopher Reyes on January 22, 8 || 2021. The Clerk of the Court properly entered the default of Christopher Reyes on January 26, 2021. 9 |] On March 3, 2021, the United States filed a motion for default judgment and final judgment of forfeiture 10 || with the Court and such filings, if/when granted, would terminate the case. No party has entered this 11 || case claiming an interest in the defendant currency. 12 For these reasons, the United States seeks to continue the deadline to file a Joint Status Report to 13 || June 14, 2021 (or to another date the Court deems appropriate). 14 Thus, there is good cause to extend the deadline to file a joint status report in this case from 15 |} April 12, 2021 to June 14, 2021, or to a date the Court deems appropriate. 16 || Dated: _ 4/7/2021 PHILLIP A. TALBERT Acting United States Attorney 18 /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN 19 Assistant U.S. Attorney 20 ORDER 21 Pursuant to the United States’ request and good cause appearing, the Court makes the following 22 || order: 23 The deadline to file a Joint Status Report currently due on April 12, 2021 is extended to June 14, 24 |! 2021. 25 IT IS SO ORDERED. oo. 26 Dated: April 8, 2021 ahhh A, han hee WILLIAM B. SHUBB 27 UNITED STATES DISTRICT JUDGE 28