[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

CHRISTINA A. SNYDER, District Judge.

This action was filed on February 27, 2018. Notice was given and published in accordance with law. Potential claimant Otoniel Sosa Cardenas ("Claimant"), who was the driver and registered owner of the vehicle from which the defendant $68,000.00 in U.S. currency ("Defendant Currency") was seized, is the sole known potential claimant to the Defendant Currency, and would have filed a timely claim if the parties had not reached a settlement. No other claims were filed to the Defendant Currency, and the time for filing claims has expired.

Plaintiff and Claimant have reached an agreement that is dispositive of the entire action. They have made a joint request that judgment be entered on the terms set out herein.

The Court has reviewed the stipulation and request of the parties to enter judgment and, good cause appearing therefor, IT IS ORDERED, ADJUDGED AND DECREED THAT:

1. This Court has jurisdiction over Plaintiff, the Defendant Currency, Claimant 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 Otoniel Sosa Cardenas are deemed to have admitted the allegations of the Complaint. The allegations set forth in the Complaint are sufficient to establish a basis for forfeiture.

3. The United States of America shall have judgment as to $63,000.00 of the Defendant Currency, plus any interest earned on the entirety of the Defendant Currency. No other person or entity shall have any right, title or interest therein. The government is ordered to dispose of said asset in accordance with law.

4. The government shall return $5,000.00 of the Defendant Currency, without interest to Otoniel Sosa Cardenas. The $5,000.00 shall be returned no later than sixty days after the date this judgment is entered, or sixty days after Otoniel Sosa Cardenas provides the information described below, whichever is later.

5. If the United States elects to make the payment by check, the check shall be payable to the "Paul L. Gabbert client trust account", and mailed to Otoniel Sosa Cardenas in care of his attorney, Paul L. Gabbert, 1717 Fourth Street, Third Floor, Santa Monica, California 90401. If the United States elects to make the payment by wire transfer, the funds shall be wire transferred to the Paul L. Gabbert Client Trust Account. Claimant agrees to provide the necessary bank account information for the trust account and her personal identifiers upon request from the United States.

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.

IT IS SO ORDERED.