Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1:08-mc-00075-IVIPT Document 1 Filed O4/08/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
IN RE :
ONE HUNDRED FIFTY THOUSAND : Miscellaneous Action No. 08-75
NINE HUNDRED DOLLARS :
IN UNITED STATES CURRENCY 1
STIPULATION AND ORDER
EXTENDING UNITED STATES' TIME TO FILE COMPLAINT FOR FORFEITURE
It is hereby stipulated by and between the United States of America and claimants
Clayton Adams and Marvin Kilgore ("claimants"), by and through their attorney, John Deckers,
Esquire, as follows:
l. On January 9, 2008, claimants filed a claim in administrative forfeiture proceedings with
the Drug Enforcement Administration ("DEA") with respect to One Hundred Fifty Thousand
Dollars in United States Currency (the "property"), which was seized on September 27, 2007.
2. The DEA has sent the written notice of intent to forfeit required by 18 U.S.C. §
983(a)(l)(A) to all known interested parties, the time has expired for any person to file a claim to
the property under 18 U.S.C. § 983(a)(2)(A)—(E), and no person other than claimants have filed a
claim to the property as required by law in thc 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 property alleging that the property is subject to forfeiture within 90 days
after a claim has been tiled in thc administrative forfeiture proceedings, which in this case would
be April 9, 2008, unless the court extends the deadline for good cause shown or by agreement of
the parties.
4. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend the
time in which the United States is required to tile a complaint for forfeiture against the property.

Case 1 :08-mc-00075-I\/IPT Document 1 Filed O4/08/2008 Page 2 of 2
6. The parties agree that the deadline by which the United States shall be required to file a
complaint for forfeiture against the property shall be extended from April 9, 2008, to April 16,
2008.
@:4 John Dickers, Esquire
800 North King Street, Suite 302
Wilmington, Delaware 19801
Attorney for Claimants
(302) 656-9850
COLM F. CONNOLLY
Unite tates Attorney
By: J C f/LU
Douglas E. cCann
Assistant United States Attorney
1007 Orange Street
Wilmington, Delaware 19801
(302) 573-6277
Assistant United States Attorney
IT IS SO ORDERED this ____ day of Ami], 9008.
{UNITED STATES MAEJSTRATE JUDGE

Case 1:08-mc-00075-MPT

Document 1

Filed 04/08/2008

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Case 1:08-mc-00075-MPT

Document 1

Filed 04/08/2008

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