[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

PERCY ANDERSON, District Judge.

This action was filed on July 30, 2015. Notice was given and published in accordance with law. Claimant Jermile Kelly ("Claimant") filed the only claim to the defendant $26,900.00 in U.S. currency (the "defendant currency") and ten U.S. Postal Service Money Orders (the "defendant money orders") (collectively, the "defendant property") which property was initially seized on or about May 1, 2014, from Jermile Kelly and Henock Andualem during a traffic stop conducted by the Los Angeles Sheriff's Department ("LASD") in Los Angeles, California. The defendant property was later seized from the LASD by the Drug Enforcement Administration ("DEA") on or about February 17, 2015, pursuant to a federal seizure warrant. 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 request that the Court enter this Consent Judgment of Forfeiture.

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 claims for relief pursuant to 21 U.S.C. § 881(a)(6), 18 U.S.C. § 981(a)(1)(A) and (C), and 31 U.S.C. § 5317(c)(2).

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 the Complaint. The allegations set out in the Complaint are sufficient to establish a basis for forfeiture.

D. The United States of America shall have judgment as to $16,900.00 of the defendant currency and all of the defendant money orders, together with all interest earned by the government on the entire amount of the defendant property since seizure, and no other person or entity shall have any right, title or interest therein.

E. $10,000.00 of the defendant currency, without any interest, shall be paid to Claimant not later than sixty (60) days from the date of entry of this judgment by electronic transfer directly into the account entitled "Roy Edward Furr, Client Trust Account." Claimant's counsel agrees to provide appropriate financial institution account information and the requisite personal identifiers within 10 days of execution of this consent judgment. Said payment shall be subject to applicable federal law.

F. Claimant has withdrawn his Petition for Remission or Mitigation submitted to the DEA, and waives any right he may have to petition for remission or mitigation of the forfeiture.

G. Claimant has released the United States of America, its agencies, agents, and officers, including employees and agents of the Drug Enforcement Agency, 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.

H. The Court finds that there was reasonable cause for the seizure of the defendant property and institution of these proceedigs. This judgment shall be construed as a certificated of reasonable cause pursuant to 28 U.S.C. &sect 2465.