[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

R. GARY KLAUSNER, District Judge.

This civil forfeiture action was commenced on November 25, 2015 against the defendants $573,054.97 in Bank of America Funds (the "Defendant Funds") and Miscellaneous Items. Claimants Kenneth B. Mauer and Danielle R. Mauer filed a claim on January 29, 2016 and an answer on February 19, 2016.

No other parties have filed claims in this case and the time for filing claims of interest and answers has expired.

Plaintiff United States of America and Claimants have reached an agreement that is dispositive of the action. The parties hereby request that the Court enter this Consent Judgment of Forfeiture.

WHEREFORE, IT IS ORDERED, ADJUDGED AND DECREED:

1. This Court has jurisdiction over the parties and the subject matter of this action.

2. Notice of this action has been given in accordance with law. All potential claimants to the defendants, other than the Claimants, 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.

3. The United States of America shall have judgment as to $533,054.97 of the Defendant Funds ("Forfeited Funds"), all of the defendant Miscellaneous Items and all interest earned on the entirety of the Defendant Funds since seizure, and no other person or entity shall have any right, title or interest therein. The Department of Homeland Security is ordered to process said defendants in accordance with law.

4. $40,000.00 of the Defendant Funds, without interest, shall be returned to Claimants by either check or wire transfer. If the United States elects to make the payment by check, the check will be payable to "Lindquist & Vennum LLP Client Trust Account," and mailed to J. Christopher Cuneo, Esq., Lindquist & Vennum LLP, 4200 IDS Center, 80 South Eighth Street, 4200 IDS Center, Minneapolis, MN 55402. If the United States elects to make the payment by wire transfer, the funds will be wire transferred to the Lindquist & Vennum LLP Client Trust Account. Claimants and their attorney shall provide any and all information, including personal identifiers, needed to process the return of these funds according to federal law.

5. Claimants agree to release the United States of America, its agencies, agents, and officers, including employees, officers and agents of the U.S. Customs and Border Protection and Immigration and Customs Enforcement from any and all claims, actions or liabilities arising out of or related to this action or the underlying seizures, including, without limitation, any claim for attorney's fees, costs or interest which may be asserted on behalf of Claimants, whether pursuant to 28 U.S.C. § 2465 or otherwise.

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