[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

CHRISTINA A. SNYDER, District Judge.

Plaintiff United States of America and potential claimants Juan Ernesto Villapudua and Lizette Guerero having made a stipulated request for the entryof judgment, and good cause appearing therefor, 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. No claims or answers have been filed and the time for filing claims and answers has expired. All potential claimants to the defendant currency other than Juan Ernesto Villapudua and Lizette Guerero 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. Pursuant to the stipulation of the parties, the United States of America shall have judgment as to $28,125.00 of the defendant currency and all interest earned on 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 is ordered to dispose of said funds in accordance with law.

4. $6,000.00 of the defendant currency, without interest, shall be returned to Juan Ernesto Villapudua and Lizette Guerero through their counsel. The United States shall return the defendant $6,000.00 not later than 45 days after (a) entry of this Judgment and (b) Juan Ernesto Villapudua's and Lizette Guerero's submission to government counsel the bank routing information and personal identifiers needed to effect the wire transfer of the funds, whichever is later.

5. Juan Ernesto Villapudua and Lizette Guerero have agreed to release the United States of America, its agencies, agents, and officers, including employees, officers and agents of the Drug Enforcement Administration, as well as all agents, officers, employees and representatives of any state or local government 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's fees, costs or interest which may be asserted on behalf of Juan Ernesto Villapudua and Lizette Guerero, whether pursuant to 28 U.S.C. § 2465 or otherwise. Juan Ernesto Villapudua and Lizette Guerero waive any rights they may have to seek remission or mitigation of the forfeiture.

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