United States District Court, E.D. Michigan, Southern Division
Matthew Schneider United States Attorney Shankar Ramamurthy
Assistant United States Attorney
Christopher W. Quinn II Attorney for Claimant
STIPULATION AND AGREEMENT FOR ENTRY OF CONSENT
JUDGMENT AND FINAL ORDER OF FORFEITURE AS TO CLAIMANT DEMOND
Honorable Hon. Terrence Berg, United States District Judge.
the United States of America (hereinafter the “United
States”), by and through its counsel, Matthew
Schneider, United States Attorney for the Eastern District of
Michigan, and Shankar Ramamurthy, Assistant United States
Attorney, and Demond Gibson, by and through his attorney,
Christopher W. Quinn II, Esq., (collectively, “the
Parties”) enter into this Stipulation and Agreement for
Entry of Consent Judgment and Final Order of Forfeiture as to
Defendant in rem Eighty-Two Thousand, Three Hundred
Dollars ($82, 300) in U.S. Currency, Defendant in
rem, under the terms and conditions hereinafter set
Officers with the Drug Enforcement Administration
(“DEA”) seized the Defendant in rem on
or about January 29, 2018 at the Detroit Metropolitan Airport
in Romulus, Wayne County, Michigan.
Demond Gibson, (“Claimant”) filed an
administrative claim and Petition for Remission or Mitigation
with the DEA, and thereafter, DEA referred the matter to the
United States Attorney's Office for judicial forfeiture.
June 11, 2018, the United States of America filed a verified
Complaint for Forfeiture against the Defendant in
rem, pursuant to 21 U.S.C § 881(a)(6). (ECF No. 1).
July 10, 2018, Claimant Demond Gibson, through counsel, filed
a an Answer and Affirmative Defenses to Plaintiff's
Complaint for Forfeiture. (ECF No. 5).
July 11, 2018, Claimant Demond Gibson, through counsel, filed
a Motion and Brief to Dismiss Plaintiff's Complaint for
Forfeiture in rem. (ECF No. 6). The United States
filed a Response to the Motion to Dismiss on July 11, 2018.
(ECF No. 7).
July 30, 2018, Claimant Demond Gibson, through counsel, filed
a Verified Claim. (ECF No. 9).
United States filed its Declaration of Publication of the
civil judicial forfeiture action on or about August 14, 2018.
(ECF No. 10).
United States filed a Motion to Strike the Claim on August
30, 2018 (ECF No. 14), to which Claimant filed a Response to
on September 7, 2018. (ECF No. 16). The United States filed
its Reply in Support of United States' Motion to Strike
Claim and Dismiss Interest on September 12, 2018. (ECF No.
17). The Court entered an Order Denying Government's
Motion to Dismiss Claim for Lack of Standing and Denying
Claimant's Motion to Dismiss Complaint on March 11, 2019.
(ECF No. 18).
other verified claims of interest to the Defendant in
rem have been filed in this judicial action, and the
time for filing such pleadings has expired. Plaintiff, the
United States of America, and Claimant Demond Gibson, by and
through his attorney, Christopher W. Quinn II, (“the
parties”) wish to resolve this matter without further
litigation and expense.
THEREFORE, IT IS STIPULATED by and between the