United States v. Approximately $30,000.00 in U.S. Currency

Filing 18

STIPULATION to Continue Discovery and Disclosure Dates; ORDER Thereon re 17 signed by Magistrate Judge Gary S. Austin on 6/12/2014. Nonexpert Discovery due by 12/5/2014; Expert Disclosure due by 12/5/2014; Supplemental Expert Disclosure due by 1/2/2015; Expert Discovery due by 2/3/2015; Non-Dispositive Motions filed by 2/17/2015.(Martinez, A)

1 BENJAMIN B. WAGNER
United States Attorney
2 JEFFREY A. SPIVAK
Assistant United States Attorney
3 United States Courthouse
2500 Tulare Street, Suite 4401
4 Fresno, California 93721
Telephone: [phone]
5 Facsimile: [phone]
6 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,

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Plaintiff,

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v.
APPROXIMATELY $30,000.00 IN U.S.
CURRENCY,
Defendant.

Case No. 1:13-CV-01542 GSA
STIPULATION TO CONTINUE DISCOVERY
AND DISCLOSURE DATES; ORDER
THEREON
DOC. 17

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The United States and Claimant Alfonso Ramos (“Ramos”), by and through their

17 attorneys of record, hereby move for a continuance of certain discovery and disclosure
18 dates currently set forth in the Court’s Scheduling Order (ECF No. 16).
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The parties jointly agree that to facilitate and complete full discovery in this case,

20 the discovery and disclosure dates currently set forth in the Joint Scheduling Report and
21 the Court’s Scheduling Order issued pursuant thereto should be extended. Such extension

22 will have no effect on the trial date in this case.
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Stipulation to Continue Discovery and Disclosure Dates;
Order Thereon

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The parties hereby stipulate and propose that the dates set forth in the Court’s

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2 Scheduling Order (ECF No. 16) should be changed to the following dates:
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Scheduling Order Date

Current Date/Deadline

Non-Expert Discovery
Cutoff
Expert Disclosure
Supplemental Expert
Disclosure
Expert Discovery Cutoff
Non-Dispositive Motion
Filing
Dispositive Motion Filing
Pre-Trial Conference Date
Jury Trial Date

Proposed New Date

July 11, 2014

December 5, 2014

August 8, 2014

December 5, 2014

September 8, 2014

January 2, 2015

November 7, 2014

February 3, 2015

December 12, 2014

March 3, 2015

April 3, 2015
July 10, 2015
September 9, 2015

No change
No change
No change

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Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney

DATED: June 10, 2014

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

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DATED: June 10, 2014

/s/ Charles A. Pacheco d
CHARLES A. PACHECO
Attorney for Claimant
Alfonso Ramos
(Original signature retained by
attorney)

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ORDER

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The Court adopts the parties’ stipulation set forth above, with the exception that
the non-dispositive motion filing date is extended from December 12, 2014 to February 17,
2015.

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Dated:

June 12, 2014

Stipulation to Continue Discovery and Disclosure Dates;
Order Thereon

/s/ Gary S. Austin
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UNITED STATES MAGISTRATE JUDGE

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Stipulation to Continue Discovery and Disclosure Dates;
Order Thereon

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