United States of America v. Real property located at 15438 Old Toll Road, Camptonville, California, APN: 064-210-041

Filing 35

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 11/22/2011 MODIFYING 18 Status (Pretrial Scheduling) Order: Discovery due by 12/9/2011, Disclosure of Expert Witnesses due by 12/23/2011. (Michel, G)

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BENJAMIN B. WAGNER
United States Attorney
KEVIN C. KHASIGIAN
Assistant U.S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: [phone]

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Attorneys for the United States

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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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UNITED STATES OF AMERICA,
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Plaintiff,
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v.
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REAL PROPERTY LOCATED AT 15438
OLD TOLL ROAD, CAMPTONVILLE,
CALIFORNIA, YUBA COUNTY,
APN: 064-210-041, INCLUDING
ALL APPURTENANCES AND
IMPROVEMENTS THERETO,

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Defendant.

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2:11-CV-00099-GEB-KJN
STIPULATION TO CONTINUE
SCHEDULING DATES AND ORDER
THEREON
(First Request)

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Claimant Gregory S. McClellan and plaintiff United States of
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America, by and through their undersigned attorneys, hereby
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stipulate as follows:
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1.

This stipulation is executed by all parties who have

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appeared in and are affected by this action.
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2.

The parties are requesting a brief extension of the

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discovery dates set out in the Scheduling Conference Order due to
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unavailability of counsel on said dates, to synchronize discovery
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efforts in this case and the related case, United States v. Real
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Property Located at 15340 Old Toll Road, Camtonville, California,
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Stip and Order to Continue
Scheduling Dates

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Case No: 2:11-CV-00091-GEB-KJN.1

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scheduling conference, counsel has been unavailable for

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depositions and requires additional time to respond to discovery

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due to pressing business on other cases.

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coordinating the discovery schedules in the two related cases

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reduces litigation expense and streamlines the discovery process.

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This is the Parties’ first request for an extension.

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Since the time of the initial

In addition,

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Each civil forfeiture action originates from the same law
enforcement investigation and action, a federal search warrant
executed on September 16, 2010. See Doc. 1, 2:11-CV-00091-GEBKJN; Doc. 1, 2:11-CV-00099-GEB-KJN. The related cases proceed on
dissimilar discovery tracks given the litigation on an unrelated
issue. Gregory S. McClellan filed his claim in Case No. 2:11-CV00099-GEB-KJN on September 1, 2011.
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Stip and Order to Continue
Scheduling Dates

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3.

The following dates are agreed on by the parties:

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Event

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Non-Expert

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Discovery

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Deadline

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Designation of

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Expert Witnesses

Existing Date

Proposed Date

November 1, 2011

December 9, 2011

November 22, 2011

December 23, 2011

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Dated: 10/28/11

BENJAMIN B. WAGNER
United States Attorney

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By:

/s/ Kevin C. Khasigian
KEVIN C. KHASIGIAN
Assistant U.S. Attorney

By:

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/s/ Stephen A. Munkelt
STEPHEN A. MUNKELT
Attorney for Claimant
Gregory S. McClellan

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Dated: 10/28/11

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(Original signatures
retained by attorney)

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ORDER
IT IS SO ORDERED.

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Dated:

November 22, 2011

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GARLAND E. BURRELL, JR.
United States District Judge

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Stip and Order to Continue
Scheduling Dates