United States of America v. Approximately $16,923.70 in U.S. Currency

Filing 12

STIPULATION and ORDER signed by Judge William B. Shubb on 11/24/09: The parties shall submit a joint status report on or before December 21, 2009. Scheduling Conference continued to 1/11/2010 at 02:00 PM in Courtroom 5 (WBS) before Judge William B. Shubb. (Kaminski, H)

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BENJAMIN B. WAGNER United States Attorney SARALYN M. ANG-OLSON, SBN 197404 Special Assistant U.S. 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 $16,923.70 IN ) U.S. CURRENCY, ) ) Defendant. ) ________________________________)

2:09-cv-02087-WBS-EFB STIPULATED REQUEST FOR EXTENSION OF TIME TO FILE JOINT STATUS REPORT; PROPOSED ORDER

Pursuant to Rule 6-144(a) of the Local Rules of Practice for the United States District Court, Eastern District of California, Plaintiff United States of America ("Plaintiff") and claimants Eric Engstrom and Mona Colomb ("Claimants"), by and through their respective counsel, hereby request that the joint status report currently due on November 30, 2009 be continued for approximately 15 days, or effectively be due on December 15, 2009. Plaintiff and Claimants make this request for the following reasons: Plaintiff and Claimants are in the process of

determining a resolution to this dispute, including gathering further pertinent information and conferring about such information between their counsel. Under the circumstances, both

Plaintiff and Claimants agree that counsel for the parties are not in a position to contribute meaningfully either to the

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process of conferring on the matter as required by Fed. R. Civ. P. 26(f) or to the preparation of a resulting joint status report as required by the Court's Order on July 29, 2009. As soon as the need has become apparent, Plaintiff and Claimants without delay, hereby make their request pursuant to Rule 6-144(d). See L. R. 6-144(d). As further required pursuant

to Rule 6-144(b), the Plaintiff and Claimants hereby represent that no prior extension of time has been previously sought in regard to the filing of the joint status report. 6-144(b). Dated: November 24, 2009 BENJAMIN B. WAGNER United States Attorney /s/ Saralyn M. Ang-Olson Saralyn M. Ang-Olson Special Assistant U.S. Attorney Dated: November 24, 2009 /s/ Stephen A. Munkelt Stephen A. Munkelt Attorney for Claimants Eric Engstrom and Mona Colomb (Original signature on file) ORDER For the reasons set forth above, the parties shall submit a joint status report on or before December 21, 2009. The See L. R.

Scheduling Conference is continued to January 11, 2010 at 2:00 p.m. Dated: IT IS SO ORDERED. November 24, 2009