United States v. Approximately $77,000.00 in U.S. Currency

Filing 48

FIRST AMENDED STIPULATION to Continue FRCP Rule 16(b) Scheduling Order Discovery Dates and ORDER signed by Magistrate Judge Gary S. Austin on 1/28/2013. Deadlines extended as follows: Non-Expert Discovery due by 3/22/2013; Expert Disclosure due by 4/5/2013; Supplemental Expert Disclosure due by 4/19/2013; Expert Discovery due by 5/13/2013; Non-Dispositive Motions filed by 5/20/2013.(Martinez, A)

5

BENJAMIN B. WAGNER
United States Attorney
HEATHER MARDEL JONES
Assistant United States Attorney
United States Courthouse
2500 Tulare Street, Suite 4401
Fresno, California 93721
[phone] Telephone
[phone] Facsimile

6

Attorneys for the United States

1
2
3
4

7
8

IN THE UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

UNITED STATES OF AMERICA,
Plaintiff,

12
13
14
15

v.
APPROXIMATELY $77,000.00 IN U.S.
CURRENCY,
Defendant.

16
17
18
19

)
)
)
)
)
)
)
)
)
)
)

1:11-CV-01251-GSA
FIRST AMENDED STIPULATION
TO CONTINUE FRCP RULE 16(b)
SCHEDULING ORDER DISCOVERY
DATES AND ORDER

IT IS HEREBY STIPULATED by and between the United States of America,
claimant Felix Velasco, and his counsel of record, as follows:
On April 25, 2012, the parties to this matter submitted their Joint Scheduling Report

20

setting forth the various discovery, disclosure, and dispositive motion dates, as required

21

pursuant to FRCP Rule 16(b);

22

The parties now jointly agree that to facilitate and complete full discovery and

23

disclosure of said discovery, the discovery and disclosure dates currently set forth in the

24

Joint Scheduling Report and the Court’s Scheduling Order issued pursuant thereto should

25

be extended approximately thirty (30) days;

26
27
28

That extension of the discovery dates will not affect the trial or pre-trial motion dates
set forth in the Scheduling Order;
The parties hereby stipulate that the dates set forth in the parties’ Joint Scheduling

29
30

1

Stipulation to Continue FRCP Rule 16(b)
Scheduling Order Discovery Dates and Order

1

Report and in the Court’s May 3, 2012 Scheduling Order (Doc. 42) should be changed to

2

the following dates:

3
Discovery Event

4
5
6
7

Current Date/Deadline

Proposed New Date

Non-Expert Discovery

February 20, 2013

March 22, 2013

Expert Disclosure
Supplemental Expert
Disclosure
Expert Discovery

March 6, 2013
March 20, 2013
April 5, 2013

April 5, 2013
April 19, 2013
May 13, 2013

8

In the alternative, if it is the Court’s preference that the parties stipulate to continue

9

all dates within the Scheduling Order an additional 30 days, a further amended stipulation

10

shall be filed.
Respectfully submitted,

11
12

DATED: January 25, 2013

13

BENJAMIN B. WAGNER
United States Attorney

14
/s/ Heather Mardel Jones
HEATHER MARDEL JONES
Assistant United States Attorney

15
16
17
18

DATED: January 25, 2013

19
20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

/s/ Edward M. Burch
EDWARD M. BURCH
Attorney for Claimant Felix Velasco
(Original signature retained by attorney)

///

29
30

2

Stipulation to Continue FRCP Rule 16(b)
Scheduling Order Discovery Dates and Order

ORDER

1

All discovery dates currently set forth in the Court’s May 3, 2012 Scheduling Order

2
3

(Doc. 42) shall be rescheduled to those dates stipulated to by the parties, as set forth above.

4

Additionally, the parties are advised that the deadline for filing of non-dispositive

5

motions is extended until May 20, 2013, to accommodate for the expert discovery

6

deadline. All other deadlines for filing dispositive motions, the pretrial conference and the

7

trial remain as set forth in the scheduling order issued on May 3, 2012. (Doc. 42). All other

8

orders in the scheduling order remain in full force and effect.

9
10
11

IT IS SO ORDERED.
Dated:

12

January 28, 2013

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

DEAC_Sign ature-END:

13
14

6i0kij8d

15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

3

Stipulation to Continue FRCP Rule 16(b)
Scheduling Order Discovery Dates and Order