CONSENT JUDGMENT OF FORFEITURE

WILLIAM B. SHUBB, District Judge.

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

1. On March 14, 2013, agents with the Internal Revenue Service — Criminal Investigation ("IRS-CI") executed a Federal seizure warrant at Wells Fargo Bank at 3220 Arena Blvd., Sacramento, California. The agents seized Approximately $58,300.00 in U.S. Currency from Wells Fargo Bank Personal Money Market Savings Account Number 6248766716 and Approximately $18,462.71 in U.S. Currency from Wells Fargo Bank Personal Money Market Savings Account Number 2449282355 (the "defendant funds").

2. The IRS-CI commenced administrative forfeiture proceedings, sending direct notice to all known potential claimants and publishing notice to all others. On or about May 1, 2013, the IRS-CI received claims from Angel Rios and Yolanda Cornejo De Rios asserting an ownership interest in the defendant funds.

3. The United States represents that it could show at a forfeiture trial that from December 10, 2012 to December 18, 2012, Angel Rios, Yolanda Cornejo De Rios or another person acting for their benefit, structured transactions by breaking up currency deposits to the Wells Fargo Bank Money Market Savings Account Numbers 6248766716 and 2449282355. The defendant funds were allegedly used to structure currency deposit transactions by breaking them into amounts at or below $10,000.00 to avoid the currency transaction requirement in violation of 31 U.S.C. § 5324(a)(3).

4. The United States could further show at a forfeiture trial that the defendant funds are forfeitable to the United States pursuant to 18 U.S.C. § 984 and 31 U.S.C. § 5317(c)(2), incorporating the procedures governing civil forfeiture actions pursuant to 18 U.S.C. § 981.

5. Without admitting the truth of the factual assertions contained in this stipulation, Angel Rios and Yolanda Cornejo De Rios specifically deny the same, and for the purpose of reaching an amicable resolution and compromise of this matter, Angel Rios and Yolanda Cornejo De Rios agree that an adequate factual basis exists to support forfeiture of the defendant funds. Angel Rios and Yolanda Cornejo De Rios hereby acknowledge that they are the sole owner of the defendant funds, 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 funds, Angel Rios and Yolanda Cornejo De Rios shall hold harmless and indemnify the United States, as set forth below.

6. 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 omissions giving rise to the forfeiture occurred.

7. This Court has venue pursuant to 28 U.S.C. § 1395, as this is the judicial district in which some of the defendant funds were seized.

8. The parties herein desire to settle this matter pursuant to the terms of a duly executed Stipulation for Consent Judgment of Forfeiture.

Based upon the above findings, and the files and records of the Court, it is hereby ORDERED AND ADJUDGED:

10. Upon entry of the Consent Judgment of Forfeiture, all of the $58,300.00 in U.S. Currency seized from Wells Fargo Bank Personal Money Market Savings Account Number 6248766716 and $3,110.17 of the Approximately $18,462.71 in U.S. Currency seized from Wells Fargo Bank Personal Money Market Savings Account Number 2449282355, together with any interest that may have accrued on the total amount seized, shall be forfeited to the United States pursuant to 18 U.S.C. § 984 and 31 U.S.C. § 5317(c)(2), incorporating the procedures governing civil forfeiture actions pursuant to 18 U.S.C. § 981, to be disposed of according to law.

11. Upon entry of the Consent Judgment of Forfeiture, but no later than 60 days thereafter, $15,352.54 of the Approximately $18,462.71 in U.S. Currency seized from Wells Fargo Bank Personal Money Market Savings Account Number 2449282355, shall be returned to potential claimants Angel Rios and Yolanda Cornejo De Rios through their attorney Donald H. Heller.

12. Plaintiff United States of America and its servants, agents, and employees and all other public entities, their servants, agents and employees, are released from any and all liability arising out of or in any way connected with the seizure or forfeiture of the defendant funds. This is a full and final release applying to all unknown and unanticipated injuries, and/or damages arising out of said seizure or forfeiture, as well as to those now known or disclosed. The potential claimants waived the provisions of California Civil Code § 1542.

13. Pursuant to Rules 408 and 410(a)(4) of the Federal Rules of evidence, no portion of this stipulated settlement, including statements or admissions made herein, shall be admissible in any criminal action.

14. All parties will bear their own costs and attorney's fees.

CERTIFICATE OF REASONABLE CAUSE

15. Pursuant to the Stipulation for Consent Judgment of Forfeiture filed herein, the Court enters this Certificate of Reasonable Cause pursuant to 28 U.S.C. § 2465, that there was reasonable cause for the seizure of the above-described defendant funds.

SO ORDERED.