STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE

WILLIAM B. SHUBB, District Judge.

It is hereby stipulated by and between the United States of America and claimant Janet Paniagua ("claimant" or "Paniagua"), by and through their respective counsel, as follows:

1. On or about December 8, 2016, claimant Paniagua filed a claim in the administrative forfeiture proceedings with the Federal Bureau of Investigation ("FBI") with respect to the Approximately $138,531.79 in Escrow Proceeds of 2306 Nightingale Ave., Stockton, California hereafter "defendant currency"), which was seized on September 2, 2016.

2. The FBI has sent the written notice of intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the defendant currency as required by law in the 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 defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the parties. That deadline was March 8, 2017.

4. By Stipulation and Order filed March 3, 2017, the parties stipulated to extend to June 6, 2017, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

5. By Stipulation and Order filed May 31, 2017, the parties stipulated to extend to September 5, 2017, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

6. By Stipulation and Order filed August 31, 2017, the parties stipulated to extend to October 5, 2017, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

7. By Stipulation and Order filed October 10, 2017, the parties stipulated to extend to November 6, 2017, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

8. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement to extend to January 5, 2018, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

9. Accordingly, the parties agree that the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture shall be extended to January 5, 2018.