USA v. Approximately $133,803.53 in U.S. Currency seized from Washington Mutual Bank et al

Filing 20

STIPULATION and ORDER signed by Judge Frank C. Damrell, Jr on 7/27/09 re 19 ORDERING that the parties shall submit a further Joint Status Report on or before August 18, 2009. (Duong, D)

1 LAWRENCE G. BROWN Acting United States Attorney 2 SARALYN M. ANG-OLSON, SBN 197404 Special 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 20 21 22 ) ) Plaintiff, ) ) v. ) ) APPROXIMATELY $133,803.53 IN U.S. ) CURRENCY SEIZED FROM WASHINGTON ) MUTUAL BANK, N.A., ACCOUNT ) #4420842802, HELD IN THE NAME OF ) ADVANTAGE FINANCIAL GROUP HOLDINGS ) MANAGEMENT LLC, and ) ) APPROXIMATELY $328,495.75 IN U.S. ) CURRENCY SEIZED FROM WASHINGTON ) MUTUAL BANK, N.A., ACCOUNT ) #4412174338, HELD IN THE NAME OF ) LOOMIS WEALTH SOLUTIONS LLC, ) ) Defendants. ) ) 2:09-CV-00461-FCD-KJM STIPULATED REQUEST FOR EXTENSION OF TIME TO FILE FURTHER JOINT STATUS REPORT; ORDER IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

Pursuant to Rule 6-144(a) of the Local Rules of Practice for

23 the United States District Court, Eastern District of California, 24 Plaintiff United States of America ("Plaintiff") and claimant 25 Flagstar Bank ("Flagstar") (collectively, the "Parties"), by and 26 through their respective counsel, agree to and hereby request 27 that the further joint status report currently due on July 30, 28 2009, pursuant to the Court's Order filed on May 21, 2009, be

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Extension of Time Joint Status Report

1 continued for approximately 19 days, or effectively be due on 2 August 18, 2009. 3 The Parties make this request for the following reason:

4 Plaintiff and Flagstar are in the process of exploring possible 5 options for resolving this dispute. To help inform that process,

6 counsel for both Parties are investigating possible options in 7 the effort to determine the feasibility and/or advisability of 8 various possible outcomes. Under the circumstances, the Parties

9 are not in a position to contribute meaningfully either to the 10 process of conferring on the matter as required by Fed. R. Civ. 11 P. 26(f) or to the preparation of a resulting joint status report 12 that outlines discovery and other plans of proceeding in 13 litigation as anticipated by the Court's Order on April 9, 2009. 14 As soon as the need has become apparent, the Parties without

15 delay hereby make their request pursuant to Rule 6-144(d). 16 See L. R. 6-144(d). 17 The Parties have previously sought and received one prior

18 extension of a period of 60 days to file a joint status report. 19 See L. R. 6-144(b). 20 Date: July 27, 2009 21 22 23 24 25 Date: July 23, 2009 26 27 28 /s/ Janet Sherman JANET SHERMAN Attorney for Claimant Flagstar Bank (Attorney signature retained on file) 2 LAWRENCE G. BROWN Acting United States Attorney

/s/ Saralyn M. Ang-Olson SARALYN M. ANG-OLSON Special Assistant U.S. Attorney

Extension of Time Joint Status Report

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ORDER For the reasons set forth above, the Parties shall submit a

3 further Joint Status Report on or before August 18, 2009. 4 5 6 7 Dated: July 27, 2009 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FRANK C. DAMRELL, JR. UNITED STATES DISTRICT JUDGE IT IS SO ORDERED.

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Extension of Time Joint Status Report