USA v. Approximately $26,335.71 in US Currency Seized from Umpqua Bank

Filing 11

STIPULATION and ORDER signed by Judge Morrison C. England, Jr on 2/6/2009 7 ORDERING that the joint status report currently due on February 9, 2009 be CONTINUED for approximately 60 days, or effectively until by 4/10/2009. (Reader, L)

1 LAWRENCE G. BROWN Acting United States Attorney 2 SARALYN M. ANG-OLSON, SBN 197404 Assistant United States Attorney 3 501 I Street, Suite 10-100 Sacramento, CA 95814 4 Telephone: [phone] Attorneys for Plaintiff United States of America 6 7 8 9 10 11 UNITED STATES OF AMERICA, 12 13 14 15 16 17 18 19 Plaintiff United States of America and claimants Enrique ) ) Plaintiff, ) ) v. ) ) APPROXIMATELY $26,335.71 IN ) U.S. CURRENCY SEIZED FROM ) UMPQUA BANK ACCOUNT NUMBER ) 990492050 HELD IN THE NAME OF ) GARCIA'S MEATS, ) ) Defendant. ) ______________________________) 2:08-cv-02858-MCE-EFB STIPULATION FOR EXTENSION OF TIME TO FILE JOINT STATUS REPORT AND ORDER [PROPOSED] IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

DATE: N/A TIME: N/A COURTROOM: N/A

20 Garcia and Eva Cervantes ("Claimants"), by and through their 21 respective counsel, hereby request that the joint status report 22 currently due on February 9, 2009 be continued for approximately 23 60 days, or effectively until April 10, 2009. 24 Plaintiff and Claimants make this request for the following Plaintiff and Claimants had agreed to extend Claimants'

25 reasons:

26 time to file their claim to the defendant currency to February 9, 27 2009. Because Claimants' counsel is currently still in the

28 process of preparing his clients' claim and answer in this 1

1 action, he is not in a position to contribute meaningfully to the 2 process of conferring on the matter as required by Fed. R. Civ. 3 P. 26(f) and to the preparation of a resulting joint status 4 report as required by the Court's Order on November 25, 2008. 5 As soon as the need became apparent, counsel for Plaintiff

6 and Claimants conferred about an extension of time to file the 7 joint status report and, without delay, hereby make their 8 request. 9 As required under Rule 6-144(b) of the Local Rules of

10 Practice for the United States District Court, Eastern District 11 of California, the Plaintiff and Claimants hereby represent that 12 no prior extensions of time have been sought in regard to the 13 filing of the joint status report. 14 Dated: February 4, 2009 15 16 17 18 19 Dated: February 4, 2009 20 21 22 23 24 25 26 27 28 2 Dated: February 6, 2009 _____________________________ MORRISON C. ENGLAND, JR. UNITED STATES DISTRICT JUDGE IT IS SO ORDERED. ORDER /s/ Gilbert Roque Gilbert A. Roque Attorney for Claimants Enrique Garcia /s/ Saralyn M. Ang-Olson Saralyn M. Ang-Olson Special Assistant U.S. Attorney LAWRENCE G. BROWN Acting United States Attorney