[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

STEPHEN V. WILSON, District Judge.

This action was filed on September 13, 2006.1 Notice was given and published in accordance with law. Claimant Adonis Gladney ("Claimant") filed the only claims to the defendant $74,038.00 in U.S. currency (the "defendant currency") and the defendant specially constructed Lamborghini Diablo and specially constructed Lamborghini Murcielago (the "defendant vehicles") (collectively the "defendant property"), which were seized on or about April 19, 2006. No other statements of interest or answers have been filed, and the time for filing such statements of interest and answers has expired. Plaintiff and Claimant have reached an agreement that is dispositive of the action. The parties have requested that the Court enter this Consent Judgment of Forfeiture.

WHERE, 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 Complaints for Forfeiture each state a claim for relief pursuant to 18 U.S.C. § 981(a) (1) (C).

C. Notice of this action has been given in accordance with law. All potential claimants to the defendant property other than claimant are deemed to have admitted the allegations of each of the complaints. The allegations set out in the Complaints are sufficient to establish a basis for forfeiture.

D. The United States of America shall have judgment as to $71,538.00 of the defendant currency, together with all interest earned by the government on that portion of the defendant currency since seizure, and no other person or entity shall have any right, title or interest therein. The United States of America will use a portion of the $71,538.00 to satisfy the money judgment against Claimant in United States v. Adonis Gladney, CR 08-00686-RHW-1 in full.

E. $2,500.00 of the defendant currency, together with all interest earned by the government on that amount since seizure, shall be paid to Claimant. Said payment shall be subject to applicable federal law. The defendant vehicles shall be returned to Claimant or his designee in the Central District of California by the United States Marshals Service. Claimant is responsible for transporting the defendant vehicles from the custody of the United States Marshals Service.

F. Claimant has released the United States of America, its agencies, agents, and officers, including employees and agents of the Federal Bureau of Investigation, 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 which may be asserted on behalf of the Claimant, whether pursuant to 28 U.S.C. § 2465 or otherwise. Nothing in this consent judgment is intended as, nor should anything in this consent judgment be interpreted as an admission by claimant of any liability or wrongdoing.

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