[PROPOSED] CONSENT JUDGMENT

R. GARY KLAUSNER, District Judge.

The United States of America ("Plaintiff") filed a Complaint in this matter on July 3, 2013, and notice was given and published in accordance with law. Jung Min Shin and Heebok Shin ("Claimants"), the sole owners of Shin's Trading Company, Inc., filed a timely claim on behalf of Shin's Trading Company, Inc., from which corporate bank account defendant $776,670.00 in funds ("Defendant Funds") was seized. No other claims have been filed, and the time for filing claims has expired.

Plaintiff and Claimants have reached an agreement that is dispositive of the entire action, and the parties now stipulate and request that judgment be entered on the following terms.

The Court has reviewed the stipulation and request of the parties to enter judgment and, good cause appearing therefor, IT IS ORDERED, ADJUDGED AND DECREED THAT:

1. This Court has jurisdiction over Plaintiff, Defendant Funds, Claimants, and the subject matter of this action.

2. Notice of this action has been given in accordance with law, and other than Claimants, all potential claimants to Defendant Funds are deemed to have admitted the allegations of the Complaint. The allegations set forth in the Complaint are sufficient to establish a basis for forfeiture.

3. Promptly after entry of this judgment, Defendant Funds shall be paid to the client trust account ("IOLTA") maintained by Claimants' attorney, David Paek, of the Law Offices of David Paek.

4. Plaintiff, the United States of America, its agencies, agents, and officers, including employees and agents of the Drug Enforcement Administration, Internal Revenue Service, Department of Homeland Security, and local or state law enforcement officers cross-designated as agents of the United States, are released from any and all claims, actions or liabilities arising out of or related to this action, including, without limitation, any claim for attorney's fees, costs or interest that may be asserted on behalf of Claimants, whether pursuant to 28 U.S.C. § 2465 or otherwise.

5. The Court finds that there was reasonable cause for the seizure of Defendant Funds and institution of these proceedings. This judgment shall be construed as a certificate of reasonable cause pursuant to 28 U.S.C. § 2465.

IT IS SO ORDERED.