CONSENT JUDGMENT

JS-6

JOHN A. KRONSTADT, District Judge.

This action was filed on September 29, 2015 against the defendant $99,940.00 in U.S. Currency ("defendant currency"). Shirish Patel ("Patel"), from whom the defendant currency was seized, claims an interest in the defendant currency, and filed a claim and answer to the complaint on October 13, 2015. No person other than Patel is believed to have an interest therein. Notice has been given and published in accordance with the law. No other claims or answers have been filed, and the time for filing claims and answers has expired. Plaintiff United States of America and Patel have reached an agreement that is dispositive of the action, and have requested that this consent judgment be entered. Nothing in this consent judgment is intended or should be interpreted as an admission of wrongdoing by Patel.

WHEREFORE, IT IS ORDERED, ADJUDGED AND DECREED:

A. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1345 and 1355 and over the parties hereto.

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

C. Notice of this action has been given in accordance with law. All potential claimants to the defendant currency other than Patel are deemed to have admitted the allegations of the Complaint. The allegations set out in the complaint are sufficient to establish a basis for forfeiture.

D. $49,970.00 of the defendant currency, plus all interest earned on the entirety of the defendant currency since seizure, shall be and hereby is forfeited to the United States of America, which shall dispose of $49,970.00 of the defendant currency in the manner required by law.

E. $49,970.00 of the defendant currency without interest shall be returned to the claimant, Patel.

F. The funds to be returned to Patel shall, at the government's option, be returned by either check or wire transfer within 60 days of the date this Judgment is entered. If the United States elects to make the payment by check, the check will be payable to "The Law Offices of Victor Sherman client trust account," and mailed to Shirish Patel, in care of his attorney, Victor Sherman, Esq., 2115 Main Street, Santa Monica, California 90405-2215. If the United States elects to make the payment by wire transfer, the funds will be wire transferred to a bank account designated by Patel. Patel agrees to provide the necessary bank account information and personal identifiers upon request from the United States.

G. Patel hereby releases the United States of America, its agencies, agents, officers, employees and representatives, including, without limitation, all agents, officers, employees and representatives of the Drug Enforcement Administration and the Department of Justice and their respective agencies, as well as all agents, officers, employees and representatives of any state or local governmental or law enforcement agency involved in the investigation or prosecution of this matter, from any and all claims, actions or liabilities arising out of or related to this action, including, without limitation, any claim for attorney fees, costs and interest, which may be asserted by or on behalf of claimant Shirish Patel, whether pursuant to 28 U.S.C. § 2465 or otherwise. Patel waives any rights he may have to seek remission of the forfeiture ordered herein.

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