United States of America v. Approximately $4,950.00 in U.S. Currency

Filing 26

STIPULATION and ORDER signed by Senior Judge Lawrence K. Karlton on 12/14/2009 ORDERING 25 Scheduling Conference reset for 6/14/2010 at 02:00 PM in Courtroom 4 (LKK) before Senior Judge Lawrence K. Karlton; 14 days before the scheduling conference the parties will advise the court if a further stay is necessary. If the criminal case has been resolved, the parties will file a joint status report addressing the issues listed in the 2/22/2008, Order Setting Status (Pretrial Scheduling) Conference. (Reader, L)

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BENJAMIN B. WAGNER United States Attorney KRISTIN S. DOOR, SBN 84307 Assistant United States Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: [phone] Attorneys for Plaintiff United States of America

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

) ) Plaintiff, ) ) v. ) ) APPROXIMATELY $4,950.00 IN ) U.S. CURRENCY, ) ) Defendant. ) ______________________________)

2:08-cv-00395 LKK/GGH STIPULATION TO EXTEND STAY OF FURTHER PROCEEDINGS AND ORDER THEREON

DATE: December 14, 2009 Time: 1:30 p.m. COURTROOM: 4/Chambers

Plaintiff United States of America and claimants Michael Lombardo and J'lanna Morgan (formerly known as Jill Ann Lombardo jointly request that the stay of further proceedings originally entered in this case on May 1, 2008, and extended thereafter on November 6, 2008, and May 14, 2009, be extended an additional six months to June 14, 2010. The criminal case against claimant

Michael Lombardo (U.S. v. Michael Lombardo, 2:07-CR-0439 LKK) is still pending, and the next status conference is scheduled for December 22, 2009. Accordingly, the parties contend that proceeding with this action at this time has potential adverse affects on the
STIPULATION TO EXTEND STAY OF FURTHER PROCEEDINGS AND ORDER THEREON [PROPOSED]

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prosecution of the related-criminal case and/or upon claimants' ability to prove their claims to the property and to contest the government's allegations that the property is forfeitable. For

these reasons, the parties request that this matter be stayed for an additional six months. At that time the parties will advise the Court whether a further stay is necessary.

Dated: November 24, 2009

BENJAMIN B. WAGNER United States Attorney

By 11 12 13 14 15 16 By 17 18 19 20 21 22 23 24 25 26 27 28 ORDER Dated: November 29, 2009 Dated: November 25, 2009

/s/ Kristin S. Door KRISTIN S. DOOR Assistant U.S. Attorney Attorneys for Plaintiff United States of America DANIEL J. BRODERICK Federal Defender

/s/ Timothy Zindel TIMOTHY ZINDEL Assistant Federal Defender Attorney for claimant Michael Lombardo /s/ J'lanna Morgan J'LANNA MORGAN (Formerly known as JILL ANN LOMBARDO) Claimant, appearing in propria persona (Original signatures retained by AUSA Door)

For the reasons set forth above this matter is stayed pursuant to 18 U.S.C. §§ 981(g)(1), 981(g)(2) and 21 U.S.C. §
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881{i) for an additional six months. The scheduling conference scheduled for December 14, 2009, is continued to June 14, 2010 at 2:00 p.m. Fourteen days before

the scheduling conference the parties will advise the court if a further stay is necessary. If the criminal case has been

resolved, the parties will file a joint status report addressing the issues listed in the February 22, 2008, Order Setting Status (Pretrial Scheduling) Conference. IT IS SO ORDERED. Dated: December 14, 2009.

STIPULATION TO EXTEND STAY OF FURTHER PROCEEDINGS AND ORDER THEREON [PROPOSED]

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