United States v. Approximately $17,285.00 in U.S. Currency

Filing 44

STIPULATION to Continue Non-Expert Discovery Deadline; ORDER re 43 signed by Magistrate Judge Gary S. Austin on 1/7/2015. Non-Expert discovery deadline continued from 2/4/2015 to 3/13/2015.(Martinez, A)

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BENJAMIN B. WAGNER
United States Attorney
JEFFREY A. SPIVAK
Assistant United States Attorney
United States Courthouse
501 I Street, Suite 10-100
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]

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Attorney for the United States

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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,
Plaintiff,

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v.
APPROXIMATELY $17,285.00 IN U.S.
CURRENCY,
Defendant.

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1:13-CV-01074-GSA
STIPULATION TO CONTINUE
NON-EXPERT DISCOVERY
DEADLINE; ORDER
(Doc. No. 43)

IT IS HEREBY STIPULATED by and between the United States of America,
claimant Debra A. Pereira, and her counsel of record, as follows:
On January 22, 2014, the parties to this matter submitted their Joint Scheduling

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

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required pursuant to FRCP Rule 16(b) (ECF 17); On July 31, 2014 and again on September

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23, 2014, the Court granted the parties’ stipulated request to extend discovery and

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nondispositive motion dates (ECF 33, 36);

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Due to ongoing settlement negotiations, the parties request that the non-expert
discovery deadline be extended approximately 45 days;
Such extension would not affect the trial date or the dispositive motion deadline.

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

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The parties hereby stipulate to the following dates:

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Discovery Event

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Expert Disclosure
Supplemental Expert
Non-Expert Discovery
Expert Discovery
Nondispositive Motion
Filing Deadline
Dispositive Motion Filing
Deadline

Current Date/Deadline
December 5, 2014

UNCHANGED

December 6, 2014
February 4, 2015
March 13, 2015

UNCHANGED
March 13, 2015
UNCHANGED

April 10, 2015

UNCHANGED

May 4, 2015

UNCHANGED

Not Set

Not Set

August 5, 2015

UNCHANGED

September 29, 2015

UNCHANGED

Settlement Conference
Pretrial Conference

Proposed New Date

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Court Trial (3 day estimate)

Respectfully submitted,

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DATED: December 23, 2014

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/s/ Jeffrey A. Spivak
JEFFREY A. SPIVAK
Assistant United States Attorney

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DATED: December 26, 2014

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BENJAMIN B. WAGNER
United States Attorney

/s/ Raymond N. Baker
RAYMOND N. BAKER
Attorney for Claimant Debra A. Pereira
(Signature authorized by email)
ORDER

The Court adopts the parties’ stipulation as set forth above. Accordingly, the non-

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expert discovery deadline shall be continued from February 4, 2015 to March 13, 2015. All

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other discovery dates/deadlines currently set forth in the Court’s January 29, 2014

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Scheduling Order (ECF 22), as modified by the Orders to Continue FRCP Rule 16(b)

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Scheduling Order Discovery Dates (ECF 33, 36), shall remain unchanged.

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IT IS SO ORDERED.
Dated:

January 7, 2015

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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