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

Filing 22

STIPULATION to Continue Non-Expert Discovery Cut-Off; ORDER signed by Magistrate Judge Gary S. Austin on 12/5/2014. Non-Expert Discovery Cutoff extended to 2/3/2015.(Martinez, A)

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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: (559) 497-4000 5 Facsimile: (559) 497-4099 6 Attorneys for United States of America 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 13 14 v. Case No. 1:13-CV-01542-LJO-GSA STIPULATION TO CONTINUE NONEXPERT DISCOVERY CUT-OFF; ORDER APPROXIMATELY $30,000.00 IN U.S. CURRENCY, Defendant. 15 16 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) as modified by the 19 Order Continuing Scheduling Order Dates (ECF No. 18). 20 The parties jointly agree that to facilitate and complete full discovery in this case, 21 the discovery and disclosure dates currently set forth in the Joint Scheduling Report and 22 the Court’s Scheduling Order issued pursuant thereto should be extended. Such extension 23 will have no effect on the trial date in this case. 24 /// 25 /// 26 /// 27 /// 28 Stipulation to Continue Non-expert Discovery Cut-off; Order 1 The parties hereby stipulate and propose that the dates set forth in the Court’s 1 2 Scheduling Order (ECF No. 16) as modified by the Court’s subsequent Order (ECF No. 18) 3 should be changed to the following dates: Scheduling Order Date 4 5 6 7 8 9 10 11 12 Current Date/Deadline Proposed New Date Non-Expert Discovery Cutoff December 5, 2014 February 3, 2015 Expert Disclosure December 5, 2014 No change January 2, 2015 No change February 3, 2015 No change March 3, 2015 No change April 3, 2015 July 10, 2015 September 9, 2015 No change No change No change Supplemental Expert Disclosure Expert Discovery Cutoff Non-Dispositive Motion Filing Dispositive Motion Filing Pre-Trial Conference Date Jury Trial Date 13 14 Respectfully submitted, BENJAMIN B. WAGNER United States Attorney DATED: December 5, 2014 15 16 /s/ Jeffrey A. Spivak d JEFFREY A. SPIVAK Assistant United States Attorney 17 18 19 DATED: December 5, 2014 20 /s/ Charles A. Pacheco d CHARLES A. PACHECO Attorney for Claimant Alfonso Ramos 21 22 23 /// 24 /// /// 25 /// 26 /// 27 /// 28 /// Stipulation to Continue Non-expert Discovery Cut-off; Order 2 ORDER 1 2 Based on the foregoing stipulation, the non-expert discovery cut-off set forth in the 3 Court’s Scheduling Orders (ECF No. 16 and 18) shall be extended to February 3, 2015. 4 IT IS SO ORDERED. 5 6 Dated: December 5, 2014 /s/ Gary S. Austin UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation to Continue Non-expert Discovery Cut-off; Order 3

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