[PROPOSED] CONSENT JUDGMENT OF FORFEITURE

FERNANDO G. OLGUIN, District Judge.

Plaintiff United States of America, and Claimant Miguel Sillas ("Sillas"), have made a stipulated request for the entry of this Consent Judgment, resolving this action in its entirety.

The Court, having considered the stipulation and request of the parties, and good cause appearing therefor, HEREBY ORDERS, ADJUDGES AND DECREES:

1. This Court has jurisdiction over Plaintiff, the Defendant, Claimant and the subject matter of this action.

2. The government has given and published notice of this action as required by law, including Supplemental Rule G for Admiralty or Maritime Claims and Asset Forfeiture Actions, Federal Rules of Civil Procedure, and the Local Rules of this Court. All potential claimants to the defendant $819,649.00 in U.S. Currency ("defendant currency") other than Sillas are deemed to have admitted the allegations of the Complaint. Nothing in this consent judgment is intended or should be interpreted as an admission of wrongdoing by Claimant, nor should this consent judgment be admitted in any criminal proceeding against Claimant to prove any of the facts relied upon to establish reasonable cause for the seizure of the defendant funds. The allegations set forth in the Complaint are sufficient to establish a basis for forfeiture.

3. $219,640.00 of the defendant currency, without interest, shall be returned to Sillas through his counsel. The United States Marshals Service shall release said funds by wire transfer to Sillas' counsel, who shall provide the information and complete all documents requested by the United States to facilitate such payment, including bank account and routing information and personal identifiers needed to determine any right to offset pursuant to 31 U.S.C. § 3716.

4. The United States Marshals Service shall make the payment within 60 days of the entry of this judgment or its receipt of the information described above, whichever is later, and will endeavor to make the payment within 30 days of the entry of this judgment or its receipt of the information above, whichever is later.

5. The government shall have judgment as to the remaining $600,000.00 of the defendant currency, and no other person or entity shall have any right, title or interest therein. The government shall dispose of said asset in accordance with law.

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

7. Each of the parties shall bear its own fees and costs in connection with the seizure of the defendant currency and this action.

IT IS SO ORDERED.