United States of America v. Approximately $70,563.22 in U.S. Currency Seized From Mission Bank Account Number 3000288

Filing 24

STIPULATION AND ORDER Amending Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 7/23/2014. Non-Expert Discovery Cut-Off 12/30/2014; Expert Disclosure 12/2/2014; Expert Discovery Cut-Off 1/30/2015; Non-Dispositive Motion Filing De adline 2/26/2015; Dispositive Motion Filing Deadline 4/27/2015. Pretrial Conference CONTINUED to 6/17/2015 at 08:30 AM in Bakersfield at 510 19th Street (JLT) before Magistrate Judge Jennifer L. Thurston. Bench Trial CONTINUED to 9/14/2015 at 08:30 AM in Bakersfield at 510 19th Street (JLT) before Magistrate Judge Jennifer L. Thurston. (Hall, S)

1 BENJAMIN B. WAGNER
United States Attorney
2 HEATHER MARDEL JONES
Assistant United States Attorney
3 2500 Tulare Street, Suite 4401
Fresno, California 93721
4 Telephone: [phone]
Facsimile: [phone]
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Attorneys for United States of America

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,
Plaintiff,

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v.
APPROXIMATELY $70,563.22 IN U.S.
CURRENCY SEIZED FROM MISSION
BANK ACCOUNT NUMBER 3000288,

JOINT STIPULATION TO CONTINUE
SCHEDULING CONFERENCE ORDER
DATES; ORDER
(Doc. 23)

Defendant.

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Case No. 1:13-CV-00602-JLT

The United States, Claimant James Park and Potential Claimant Helen Park, by

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and through their attorney of record, hereby move for a continuance of the discovery and

20 disclosure dates currently set forth in the Court’s Scheduling Order (ECF No. 22).
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The parties jointly agree that to facilitate and complete full discovery and disclosure
of said discovery, the discovery and disclosure dates currently set forth in the Joint
Scheduling Report should be extended approximately 90 days and that the remaining

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dates in the Court’s Scheduling Order issued pursuant thereto should be extended

26 approximately 90 days;
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Since the time of the initial scheduling conference, Ellis Park, counsel for Claimant

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Stipulation to Continue Scheduling Conference Order Dates;
Order

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1

1 James Park and Potential Claimant Helen Park has undergone invasive surgery to
2 remove part of his lower right lung. Additionally, Counsel has had complications arise
3 from the surgery, has been hospitalized, and is currently under doctors care and unable to
4 meet with his clients in order to prepare discovery responses and clear dates for
5 depositions.
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Due to Attorney Park’s recent serious health issues, the parties now jointly

7 agree the discovery and disclosure dates currently set forth in the Joint Scheduling Report
8 and the Court=s Scheduling Order issued pursuant thereto should be extended
9 approximately sixty (90) days, and the remaining scheduling dates should be extended
10 ninety (90) days;
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The parties hereby stipulate and propose that the dates set forth in the Court’s

12 Scheduling Order (ECF No. 22) should be changed to the following dates:
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Scheduling Order Date

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Non-Expert Discovery Cutoff

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Expert Disclosure

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Supplemental Expert
Disclosure

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Current Date/Deadline

Proposed New Date

September 30, 2014

December 30, 2014

September 2, 2014

December 2 , 2014

No Dates Given

N.A.

Expert Discovery Cutoff

October 30, 2014

January 30, 2015

Non-Dispositive Motion
Filing

November 26, 2014

February 26, 2015

January 26, 2015

April 26, 2015

March 17, 2015

June 17, 2015

May 26, 2015

August 26, 2015

Dispositive Motion Filing

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Pre-Trial Conference Date

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Court Trial Date

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Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney

Dated: July 22, 2014

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

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Stipulation to Continue Scheduling Conference Order Dates;
Order

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1 Dated: July 22, 2014

/s/ Ellis Park
ELLIS PARK
Attorney for Claimant James Park
and Potential Claimant Helen Park

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ORDER

6 All dates currently set forth in the Court’s Scheduling Order (ECF No. 22) shall be
7 rescheduled to those dates stipulated to by the parties, as set forth hereinabove except
8 that the bench trial is set on September 14, 2015.
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10 IT IS SO ORDERED.
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Dated:

July 23, 2014

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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Stipulation to Continue Scheduling Conference Order Dates;
Order

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