United States Of America v. Approximately $8,800 in American Express Travelers' Checks et al
Filing
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ORDER TO STAY (whalc2, COURT STAFF) (Filed on 9/12/2011)
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MELINDA HAAG (CSBN 132612)
United States Attorney
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MIRANDA KANE (CSBN 150630)
Chief, Criminal Division
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DAVID B. COUNTRYMAN (CSBN 226995)
Assistant United States Attorney
450 Golden Gate Avenue, 11th Floor
San Francisco, CA 94102
Telephone: 415.436.7303
Facsimile: 415.436.7234
Email: david.countryman@usdoj.gov
Attorneys for United States of America
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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UNITED STATES OF AMERICA,
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Plaintiff,
v.
APPROXIMATELY $8,800 IN
AMERICAN EXPRESS TRAVELERS’
CHECKS; AND ONE PENTAX 35mm
CAMERA, SERIAL NUMBER 1318242,
Defendant.
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No. CV 09-02308 WHA
STIPULATION TO CONTINUE STAY
AND PROPOSED ORDER
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Plaintiff, United States of America, and Claimant Gary Hardeman respectfully submit this
Stipulation to Continue the Stay of the instant civil forfeiture action.
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On January 5, 2011, Court stayed the instant civil forfeiture case until April 7, 2011, due
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to claimant’s pending criminal prosecution: United States v. Hardeman, 10-CR-00859 RS. That
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stay was continued until September 1, 2011. As Mr. Hardeman’s criminal case is still ongoing,
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and is scheduled for trial on November 14, 2011, the parties respectfully request an additional
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stay of this case, so as not to raise the risk of self-incrimination or adversely affect the ability of
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the government to prosecute the related criminal case.
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For the aforementioned reasons, the parties respectfully request that the current case be
stayed for 120 days.
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Dated: 9/01/11
/S/ David P. Blank
DANIEL PAUL BLANK
Attorney for Claimant
Dated: 9/01/11
/S/ David B. Countryman
DAVID B. COUNTRYMAN
Assistant United States Attorney
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[PROPOSED] ORDER TO STAY
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Based upon claimant Gary Hardeman’s request to continue the stay of the current
forfeiture proceedings, the United States’ non-opposition, and for good cause appearing, it is
HEREBY ORDERED that the instant case be, and hereby is, STAYED, pursuant to 18 U.S.C.
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December 15, 2011
§ 981(g) until ____________________. A further case management conference is scheduled for
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December 15, 2011 at 11 a.m.
December 15, 2011 at 11 a.m.
______________________________________.
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SO ORDERED.
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Dated: September 12, 2011
WILLIAM H. ALSUP
United States District Judge
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STIPULATION TO CONTINUE STAY AND PROPOSED ORDER
No. CV 09-02308 WHA
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