CONSENT JUDGMENT OF FORFEITURE

MANUEL L. REAL, District Judge.

This action was filed on October 8, 2013 against the defendant $628,847.00 in U.S. currency ("defendant currency"). Binyue Xiao ("Xiao") claims an interest in the defendant currency. No other parties other than Xiao have appeared in this case and the time for filing statements of interest and answers has expired. Plaintiff United States of America and Xiao 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 defendant currency other than Xiao 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 $554,400.00 of the defendant currency and all interest earned of the entirety of the defendant currency since seizure, and no other person or entity shall have any right, title or interest therein. The United States Customs and Border Protection, Department of Homeland Security is ordered to dispose of said funds in accordance with law.

4. $74,447.00 of the defendant currency, without interest, shall be returned to Xiao by either check or wire transfer in two separate transactions: one in the amount of $65,513.36; and the second in the amount of $8,933.64. If the United States elects to make the payments by check, the check in the amount of $65,513.36 will be payable to "Binyue Xiao and Law Offices of Thomas P. Sleisenger," and mailed to attorney Thomas P. Sleisenger, Esq. at the Law Offices of Thomas P. Sleisenger, 1901 Avenue of the Stars, Suite 615, Los Angeles, California 90067. The second check in the amount of $8,933.64 will be payable to "Law Offices of Thomas P. Sleisenger," and mailed to attorney Thomas P. Sleisenger, Esq. at the Law Offices of Thomas P. Sleisenger, 1901 Avenue of the Stars, Suite 615, Los Angeles, California 90067. If the United States elects to make the payment by wire transfer, the funds will be wire transferred in two separate transactions: one in the amount of $65,513.36; and the second in the amount of $8,933.64, to the Law Offices of Thomas P. Sleisenger Client Trust Account. Xiao and his attorneys shall provide any and all information needed to process the return of these funds according to federal law.

5. Xiao has agreed to release the United States of America, its agencies, agents, and officers, including employees, officers and agents of the United States Customs and Border Protection, Homeland Security Investigations and Anaheim Police Department 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 Xiao, whether pursuant to 28 U.S.C. § 2465 or otherwise.

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