UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

UNITED STATES OF AMERICA, 

 Civil Case No. 14-13435 

 Plaintiff, 

 Honorable Victoria A. Roberts 

vs. 

TWENTY SIX THOUSAND NINE 

HUNDRED SEVENTY ONE DOLLARS 

($26,971.00) IN U.S. CURRENCY, 

 Defendant in Rem. 

_________________________________/

STIPULATION AND AGREEMENT FOR ENTRY OF 

CONSENT JUDGMENT AND FINAL ORDER OF FORFEITURE 

Plaintiff, the United States of America (hereinafter the “United States”), by 

and through its counsel, Barbara L. McQuade, United States Attorney for the 

Eastern District of Michigan, and Philip A. Ross, Assistant United States Attorney, 

and claimants, Shen Tai Yun Wu and Hsiao Jung Wu, individually, and by and 

through their attorney, Daniel J. Blank, Esq., (the United States, Shen Tai Yun Wu 

and Hsiao Jung Wu shall be referred to collectively as “the Parties”) enter into this 

Stipulation and Agreement for Entry of Consent Judgment and Final Order of 

Forfeiture as to Defendant Twenty Six Thousand Nine Hundred Seventy One 

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Dollars ($26,971.00) in U.S. Currency, (the “Defendant Currency”) under the terms 

and conditions hereinafter set forth: 

Agents with the United States Homeland Security, Customs and Border 

Protection (“CBP”), and other law enforcement agencies seized the Defendant 

Currency from Shen Tai Yun Wu at the Detroit Metropolitan Airport in Romulus, 

Wayne County, Michigan on or about March 26, 2014; 

Shen Tai Yun Wu and Hsiao Jung Wu filed administrative claims contesting 

the forfeiture with the CBP, and thereafter, CBP referred the matter to the United 

States Attorney’s Office for judicial forfeiture; 

On September 4, 2014, the United States filed a civil judicial forfeiture 

complaint against the Defendant Currency pursuant to 31 U.S.C. Section 5317(c)(2) 

(Docket #1) (the “Complaint”); 

The United States filed its Declaration of Publication of the civil judicial 

forfeiture action on or about March 17, 2015 (Docket #8); 

Claimants Shen Tai Yun Wu and Hsiao Jung Wu filed their Claim(s) of 

Ownership on October 17, 2014 (Docket #’s 4 and 5) and on November 10, 2014 

claimants Shen Tai Yun Wu and Hsiao Jung Wu filed an Answer to the Complaint 

for Forfeiture (Docket #6 ); 

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No other verified claims of interest have been filed by any party in the civil 

judicial forfeiture action, and the time for filing such claims has expired; 

Claimants Shen Tai Yun Wu and Hsiao Jung Wu agree to withdraw their 

respective claims filed in this matter; 

The Parties are aware of their respective rights and wish to resolve this action 

without further litigation and expense; 

NOW, THEREFORE, the Parties hereby stipulate and agree as follows: 

1. This action is an in rem civil forfeiture action brought pursuant to 31 

U.S.C. Section 5317(c)(2). 

2. The Court has jurisdiction and venue over this action pursuant to 28 

U.S.C. Sections 1345, 1355(b)(1)(A), 1391(b)(2), and 1395(b). 

3. The allegations of the Complaint are well taken and the United States 

and its agents had reasonable cause to seize the Defendant Currency, as provided in 

28 U.S.C. Section 2465. The position of the United States and its agents and 

employees in this action was and remains substantially justified as set forth in 28 

U.S.C. Section 2412. Claimants Shen Tai Yun Wu and Hsiao Jung Wu shall not 

claim or seek attorneys’ fees and costs in connection with this action and knowingly 

and voluntarily waives any and all claims they may have for attorneys’ fees and 

costs, whether under the Civil Asset Forfeiture Reform Act of 2000, the Equal 

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Access to Justice Act, or any other statute, rule or regulation. 

4. The Parties stipulate and agree that the following shall be 

FORFEITED to the United States pursuant to 31 U.S.C. Section 5317(c)(2): Six 

Thousand Nine Hundred Seventy One Dollars ($6,971.00) of the Defendant 

Currency seized on or about March 26, 2014, plus any interest accrued since the 

seizure date on the total amount of Defendant Currency (hereinafter, the “Forfeited 

Currency”). Any right, title or ownership interest of claimants Shen Tai Yun Wu 

and Hsiao Jung Wu and their agents, successors, assigns, and any right, title or 

ownership interest of all other persons, in the Forfeited Currency is hereby and 

forever EXTINGUISHED and clear title and all interest in the Forfeited Currency 

shall VEST in the United States, and CBP, or its delegate, is AUTHORIZED to 

dispose of the Forfeited Currency according to law. 

5. Pursuant to this Stipulation and Agreement, claimants Shen Tai Yun 

Wu and Hsiao Jung Wu agree to WITHDRAW any and all claims they have made 

for the Defendant Currency, including any administrative claims of interest and 

petitions for remission or mitigation filed with CBP. 

6. The Parties stipulate and agree that the following shall be 

RETURNED to the claimants Shen Tai Yun Wu and Hsiao Jung Wu: Twenty 

Thousand Dollars ($20,000.00) of the Defendant Currency seized on or about March 

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26, 2014. The United States agrees to release this amount, $20,000.00, to the 

claimants, Shen Tai Yun Wu and Hsiao Jung Wu, less any debt owed to the United 

States, any agency of the United States, or any other debt which the United States is 

authorized to collect from the claimants Shen Tai Yun Wu and Hsiao Jung Wu, 

including but not limited to, any debts that the United States may collect through the 

Treasury Offset Program (the “Returnable Amount”). Following entry of this 

Stipulation and Agreement by the Court, and after the claimants’ attorney has 

supplied the United States with claimants’ social security numbers, EIN numbers 

and the Automated Clearing House (“ACH”) information for electronic deposit of 

the Returnable Amount, the United States Department of Treasury, or its delegate, 

shall disburse the Returnable Amount to the claimants Shen Tai Yun Wu and Hsiao 

Jung Wu through the Electronic Payment System (“EPS”) by electronic deposit into 

the claimants attorney’s IOLTA account. 

7. Upon signing below, claimants Shen Tai Yun Wu and Hsiao Jung Wu 

agree to unconditionally release, remise and forever discharge the United States, and 

its agencies, agents, officers, and employees, past and present, and all other persons, 

including but not limited to, agents and employees of CBP, the United States 

Attorney’s Office, any individual local law enforcement officers, departments or 

agencies, and any other persons who participated in or assisted in any aspect of this 

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action and underlying investigation, from any and all actions, claims, causes of 

action, suits, proceedings, debts, dues, contracts, judgments, damages, and/or 

demands in law or equity, which the claimants Shen Tai Yun Wu and Hsiao Jung 

Wu, and/or their assignees, agents, officers, employees, heirs, or successors in 

interest had, now has or may have against the United States and its agencies, agents, 

officers, employees, past and present, and other persons involved in the seizure or 

forfeiture of the Defendant Currency, for, or on account of, the incidents or 

circumstances giving rise to any aspect of the seizure, investigation, or forfeiture 

proceedings. 

8. The Parties agree that this Stipulation and Agreement applies 

exclusively to the asset forfeiture matters arising from the seizure of the Defendant 

Currency, and in no manner immunizes the claimants Shen Tai Yun Wu and Hsiao 

Jung Wu from criminal prosecution for any illegal conduct associated with the 

Defendant Currency. 

9. By signing this Stipulation and Agreement, the claimants Shen Tai Yun 

Wu and Hsiao Jung Wu declare that they have read the terms of this Stipulation and 

Agreement, have consulted with their attorney, and fully understand the terms, 

conditions, and consequences of this Stipulation and Agreement and that they are 

aware of their rights in this forfeiture action. Claimants Shen Tai Yun Wu and Hsiao 

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Jung Wu, hereby agree to waive any attorney representation conflicts pertaining to 

this forfeiture matter, including its resolution, and are allowing Attorney Daniel J. 

Blank to represent them. Claimants Shen Tai Yun Wu and Hsiao Jung Wu warrant 

that Attorney Daniel J. Blank has discussed the issue regarding conflicts with them, 

that no conflicts exist, and that any conflicts are hereby waived if they do exist. 

10. The Parties stipulate and agree that each side shall bear its own costs 

and attorneys’ fees in this action. 

11. This Stipulation and Agreement encompasses the full agreement of the 

Parties regarding the Defendant Currency. 

12. Upon entry of this Stipulation and Agreement for Consent Judgment 

and Final Order of Forfeiture, this case shall be DISMISSED WITHOUT 

PREJUDICE. 

WHEREFORE, the Parties stipulate and agree to entry of this Stipulation and 

Agreement for Consent Judgment and Final Order of Forfeiture. 

IT IS SO ORDERED: 

S/Victoria A. Roberts 

Dated: 4/27/2015 HONORABLE VICTORIA A. ROBERTS 

United States District Court Judge 

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Agreed as to form and substance: 

BARBARA L. McQUADE 

United States Attorney 

s\Philip A. Ross s\Daniel J. Blank 

PHILIP A. ROSS DANIEL J. BLANK, ESQ. 

Assistant United States Attorney Attorney for Claimants 

211 W. Fort Street, Suite 2001 30150 Telegraph, Suite No. 444 

Detroit, Michigan 48226 Bingham Farms, Michigan 48025 

(313) 226-9790 (248) 645-1466 

Philip.ross@usdoj.gov djblankpc@yahoo.com 

[VA Bar No.70269] [P-10873] 

Dated: April 20, 2015 Dated: 

 

s\Shen Tai Yun Wu, see attached page 

SHEN TAI YUN WU 

Claimant 

Dated: April 15, 2015 

s\Hsiao Jung Wu, see attached page 

HSIAO JUNG WU 

Claimant 

Dated: April 15, 2015 

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