(Administrative Procedures Act, 5 U.S.C. §701 et seq.; U.S. Constitution, Fifth Amendment Due Process Clause)  To stay the deadlines for class members to file administrative and/or judicial forfeiture claims pursuant to 18 U.S.C. §983  and stay civil discovery until Plaintiffs’ Fourth  and Fifth Amendment challenges are determined  (Administrative Procedures Act, 5 U.S.C. §701 et seq.;  U.S. Constitution, Fifth Amendment Due Process Clause)  For an injunction and/or declaratory relief ordering Defendants to allow Plaintiff and class members to file claims to their property using a pseudonym, or that the Court appoint a special master to administer claims  (Administrative Procedures Act, 5 U.S.C. §701 et seq.,) U.S. Constitution, Fourth and Fifth Amendment, For a Preliminary and Permanent  Injunction and/or  Declaratory Relief ordering the government to return Class members’ property seized without particularized probable cause  (Administrative Procedures Act, 5 U.S.C. §701 et seq.; U.S. Constitution, Fifth Amendment Due Process Clause)  To enjoin spoliation of evidence  13. This action is properly maintainable as a class action because: a) the class is so numerous that joinder of all members is impracticable, b) there are questions of law or fact common to the class, c) the claims or defenses of the representative parties are typical of the claims or defenses of the class, and d) the representative parties will fairly and adequately protect the interests of the class, pursuant to the requirements of Federal Rule of Civil Procedure 23(a), and as set forth in detail below.  15. The Defendant government’s actions have affected the constitutional and property rights of at least 600 class members, making the class so numerous that joinder of all members is impracticable.  16. The claims and defenses of the representative Plaintiffs are typical of the class, in that their property rights were affected by the Defendant government’s improper actions described herein, and the representative Plaintiffs, like all class members, were similarly harmed by the same illegal, improper and ongoing conduct engaged in by the government.  17. The representative Plaintiffs will fairly and adequately represent and protect the interests of the members of the class, and have retained counsel who are competent and experienced in the areas of federal criminal law and procedure, asset forfeiture law, federal civil litigation and class action litigation in federal court.  There are no material conflicts between the claims of the representative Plaintiffs and the members of the class that would make class certification inappropriate.  Counsel for the class will vigorously assert the claims of all class members.  18. This class action is superior to all other methods for the fair and efficient adjudication of this controversy, because joinder of all class members is impracticable.  Furthermore, the expense and burden of individual actions makes it practically impossible for the class members to individually redress the wrongs they have suffered and may continue to suffer in the future if the conduct by the Defendant government described herein persists.  There will be  no difficulty in managing this case as a class action.  20. This action is properly maintainable as a class action because the prosecution of separate actions by individual members of the class would create a risk of inconsistent or varying adjudications with respect to individual members of the class, which would establish incompatible standards of conduct for the parties opposing the class.  21. This action also is properly maintainable as a class action because the Defendants have acted or refused to act on grounds generally applicable to the class, and such conduct is likely to reoccur against Plaintiffs and the class, thereby making appropriate final injunctive relief or corresponding declaratory relief with respect to the class as a whole. 35. Plaintiff herein incorporates by reference the acts and omissions described in Paragraphs 1-34, above.  36.  Because of the above-mentioned acts and omissions, Defendants have violated the Fourth and Fifth Amendment rights of Plaintiffs, and the rights of all other persons similarly situated, in that Defendants acted and/or failed to act in their official capacity and/or under legal authority, by improperly opening and/or searching the safe deposit boxes of Plaintiffs and the class members and seizing and/or holding their property without particularized probable cause.  37. Because of these afore-mentioned acts, and pursuant to the Administrative Procedures Act, 5 U.S.C. §701 et seq., through which the Defendants have acted to conduct the above-referenced illegal searches and seizures of the property of Plaintiff and the class members, the Defendant government should be ordered to return their property forthwith.  39.  Because of the above-mentioned acts and omissions, Defendants have violated the Fourth and Fifth Amendment rights of Plaintiffs, and the rights of all other persons similarly situated, in that Defendants acted and/or failed to act in their official capacity and/or under legal authority, by improperly opening and/or searching the safe deposit boxes of Plaintiffs and the class members and seizing and holding their property without particularized probable cause.  40. Because of these afore-mentioned acts, and pursuant to the Administrative Procedures Act, 5 U.S.C. §701 et seq., through which the Defendants have acted to conduct the above-referenced illegal searches and seizures of the property of Plaintiff and the class members, the Defendant government should be ordered to return their property forthwith, and also allow Plaintiffs and the class members to seek return of their property using a pseudonym such as “Doe.”  41. Alternatively, Plaintiffs request the Court to appoint a special master to administer class member claims seeking return of their property and/or to allow class members to file their claims under seal so they may remain anonymous to law enforcement, thereby preserving their Fifth Amendment rights.  Fed.R.Civ.P. 53(a)(1)(C). 43.  Because of the above-mentioned acts and omissions, Defendants have violated the rights of Plaintiffs, and the rights of all other persons similarly situated, in that Defendants acted and/or failed to act in their official capacity and/or under legal authority, by seizing and holding their property without particularized probable cause, and by demanding that class members identify themselves by name to seek return of their property.  44. Because of these aforementioned acts, and pursuant to the Administrative Procedures Act, 5 U.S.C. §701 et seq. and the U.S. Constitution, Fifth Amendment Due Process Clause, the Defendants should be ordered to allow, and not prohibit, class member holders of USPV safe deposit boxes to file claims to their property, including administrative and judicial forfeiture claims pursuant to 18 U.S.C. §983, using a pseudonym to identify themselves.  45. Alternatively, Plaintiffs request the Court to appoint a special master to administer class members claims seeking return of their property and/or allow class members file their claims under seal so as to them to remain anonymous to law enforcement. 46.  Plaintiff herein incorporates by reference the acts and omissions described in Paragraphs 1-45, above.  48. Because of these afore-mentioned acts, and pursuant to the Administrative Procedures Act, 5 U.S.C. §701 et seq. and the U.S. Constitution, Fourth Amendment and Fifth Amendment Due Process Clause, the Court should stay the deadlines for class members to file administrative and/or judicial forfeiture claims pursuant to 18 U.S.C. §983 and stay civil discovery until Plaintiffs’ Fourth and Fifth Amendment challenges to the box searches and property seizures are determined. 49.  Plaintiff herein incorporates by reference the acts and omissions described in Paragraphs 1-48, above.  50. Because of the above-mentioned acts and omissions, the Defendants have violated the rights of Plaintiffs, and the rights of all other persons similarly situated, in that Defendants acted and/or failed to act in its official capacity and/or under legal authority, by opening and/or searching class members’ safe deposit boxes without particularized probable cause and then requiring class members to come forward and identify themselves in administrative and judicial civil forfeiture proceedings before their Fourth and Fifth Amendment challenges of the searches and seizures are determined.  Fed.R.Crim.P. 41(g), ordering the government to return Class members’ property seized without particularized probable cause and allowing class members to remain anonymous  in seeking return of their property 