CONSENT JUDGMENT OF FORFEITURE [23]

DOLLY M. GEE, District Judge.

Plaintiff and potential claimants Tycoons Enterprise Group LLC dba Machi Footwear ("Tycoons") have made a stipulated request for the entry of this Consent Judgment, resolving this action in its entirety.

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

1. The government has given and published notice of this action as required by law, including Rule G of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rules of Civil Procedure, and the Local Rules of this Court. Potential claimants have not filed claims in this case or answered the complaint. Tycoons would have filed a claim and answer in this case absent the parties' agreement. No other statements of interest or answers have been filed by other potential claimants, and the time for filing such statements of interest and answers has expired. This Court has jurisdiction over the parties to this judgment and the defendant property. Any potential claimants to the defendant property other than Tycoons are deemed to have admitted the allegations of the complaint with respect to the defendant property.

2. Approximately 193 of the defendant cartons of ladies shoes displaying a red upper and red sole shall be returned to Tycoons through its counsel. The estimated number of such shoes is based upon invoice documents included as part of each entry packet submitted to U.S. Customs & Border Protection ("CBP"). Tycoons understands this estimate is subject to change as it may not accurately reflect the number of shoes with red soles and red uppers actually in agency custody. The shoes to be returned shall be released forthwith without payment by Tycoons of any storage or related seizure costs.

3. The remainder of the defendant cartons of shoes shall be forfeited to the government, to be disposed of according to law, and no other right, title, or interest shall exist therein.

4. Tycoons releases the United States of America, its agencies, agents, and officers, including employees and agents of CBP, from any and all claims, actions or liabilities arising out of or related to the seizure and retention of the entirety of the defendant cartons of shoes and/or the commencement of this civil forfeiture action, including, without limitation, any claim for attorneys' fees, costs or interest which may be asserted on behalf of Tycoons against the United States, whether pursuant to 28 U.S.C. § 2465 or otherwise. Tycoons waives any rights it may have to seek remission or mitigation of the forfeiture described in this stipulation and the proposed consent judgment, however nothing in this Order is intended to be, nor should it be interpreted as, an admission of any wrongdoing or waiver of any other rights by Tycoons.

5. The Court finds that there was reasonable cause for the institution of these proceedings pursuant to 28 U.S.C. § 2465. This judgment constitutes a certificate of reasonable cause pursuant to 28 U.S.C. § 2465.