SETTLEMENT AGREEMENT AND STIPULATED DISMISSAL

MARIA-ELENA JAMES, District Judge.

IT IS HEREBY STIPULATED by and between plaintiff United States of America and claimant Johnny Huynh ("Claimant," collectively the "`parties"), through their respective counsel of record, to compromise and settle their interests in the following described defendant property: approximately $139,995 in U.S. currency seized from Johnny Huynh on September 21, 2015.

1. On or about December 31, 2015, plaintiff United States of America filed its Complaint for Forfeiture against the defendant currency. After proper notification and publication was given, Johnny Huynh filed the only timely claim in this action.

2. The parties agree that the resolution of the lawsuit is based solely on the terms stated in this Settlement Agreement. It is expressly understood that this Agreement has been freely and voluntarily entered into by the parties. The parties further agree that there are no express or implied terms or conditions of settlement, whether oral or written other than those set forth in this Agreement. This Agreement shall not be modified or supplemented except in writing signed by the parties. The parties have entered into this Settlement Agreement in lieu of continued protracted litigation and District Court adjudication.

3. This settlement is a compromise over disputed issues and does not constitute any admission of wrongdoing or liability by any party.

4. Mr. Huynh asserts that he is the sole owner of the defendant currency.

5. The parties hereby stipulate to the dismissal of the instant civil forfeiture acting pursuant to the provisions of Rule 41(a)(1)(A)(ii) of the Federal Rules and Civil Procedure.

6. Mr. Huynh his heirs, representatives and assignees, agree to hold harmless the United States any and all agents, officers. For any and all claims defenses actions or liabilities arising out of or related to this action against the defendant currency.

7. The parties agree that each party shall pay it own attorneys' fees and costs.

IT IS SO STIPULATED.

Dated: JOHNNY HUYNH Claimant Dated: 3/28/16 DAVID M. MICHAEL. ESQ. Attorney for Claimant Dated: 3/30/2016 DAVID B. COUNTRYMAN Assistant Untied States Attorney