[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

CHRISTINA A. SNYDER, District Judge.

Plaintiff United States of America ("the government") and Claimant Jose Candelario Leon Beltran ("Beltran") have made a stipulated request for the entry of this Consent Judgment, resolving this action in its entirety.

The Court, having considered the stipulation of the parties, and good cause appearing therefor, HEREBY ORDERS, ADJUDGES AND DECREES:

1. This Court has jurisdiction over the subject matter of this action and the parties to this Consent Judgment of Forfeiture.

2. The Complaint for Forfeiture states a claim for relief pursuant to 21 U.S.C. § 881(a)(6).

3. Notice of this action has been given and published as required by law. All potential claimants to the defendant currency other than Beltran are deemed to have admitted the allegations of the Complaint for Forfeiture to be true with respect to the defendant currency. The allegations set out in the Complaint are sufficient to establish a basis for forfeiture.

4. The sum of $229,586.40 only (without interest) shall be returned to Beltran through his counsel. The government shall have judgment as to the remainder of the defendant currency (i.e., $344,379.60), plus any interest earned by the government on the defendant currency since seizure, and no other right, title or interest shall exist therein. The government shall dispose of the forfeited funds in accordance with law.

5. The funds to be returned to Beltran shall be paid through his counsel by electronic transfer. Beltran and his attorney shall provide all information and complete all documents requested by the government to facilitate the transfer including, without limitation, providing Beltran's social security or taxpayer identification number, the identity of the bank, and the bank's address, account name, account number, account type and routing number for the account to which the transfer of funds is to be made.

6. There was reasonable cause for the seizure of the defendant currency and institution of these proceedings. This judgment shall be construed as a certificate of reasonable cause pursuant to 28 U.S.C. § 2465.

7. Beltran did not substantially prevail in this action, and the parties hereto shall bear their own attorney fees and costs.