STIPULATION AND ORDER EXTENDING TIME FOR FILING A COMPLAINT FOR FORFEITURE AND/OR TO OBTAIN AN INDICTMENT ALLEGING FORFEITURE

GARLAND E. BURRELL, Jr., Senior District Judge.

It is hereby stipulated by and between the United States of America and claimant Dung H. Nguyen ("claimant"), by and through their respective counsel, as follows:

1. On or about March 22, 2012, claimant Dung H. Nguyen filed a claim, in the administrative forfeiture proceedings, with the Internal Revenue Service — Criminal Investigation with respect to the Approximately $149,000.00 (hereafter "defendant currency"), which was seized on March 5, 2012.

2. The Internal Revenue Service — Criminal Investigation has sent the written notice of intent to forfeit required by 18 U.S.C. § 983(a)(1)(A) to all known interested parties. The time has expired for any person to file a claim to the defendant currency under 18 U.S.C. § 983(a)(2)(A)-(E), and no person other than the claimant has filed a claim to the defendant currency as required by law in the administrative forfeiture proceeding.

3. Under 18 U.S.C. § 983(a)(3)(A), the United States is required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture within ninety days after a claim has been filed in the administrative forfeiture proceedings, unless the court extends the deadline for good cause shown or by agreement of the parties. That deadline was June 20, 2012.

4. By Stipulation and Order filed June 18, 2012, the parties stipulated to extend to August 20, 2012, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

5. By Stipulation and Order filed August 14, 2012, the parties stipulated to extend to October 20, 2012, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

6. As provided in 18 U.S.C. § 983(a)(3)(A), the parties wish by agreement for an extension to November 20, 2012, the time in which the United States is required to file a civil complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture.

7. Accordingly, the parties agree that the deadline by which the United States shall be required to file a complaint for forfeiture against the defendant currency and/or to obtain an indictment alleging that the defendant currency is subject to forfeiture shall be extended to November 20, 2012.

IT IS SO ORDERED.