United States Of America v. Approximately $8,800 in American Express Travelers' Checks et al

Filing 38

ORDER TO STAY (whalc2, COURT STAFF) (Filed on 9/12/2011)

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1 2 MELINDA HAAG (CSBN 132612) United States Attorney 3 MIRANDA KANE (CSBN 150630) Chief, Criminal Division 4 5 6 7 8 9 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 10 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 UNITED STATES OF AMERICA, 14 15 16 17 18 19 Plaintiff, v. APPROXIMATELY $8,800 IN AMERICAN EXPRESS TRAVELERS’ CHECKS; AND ONE PENTAX 35mm CAMERA, SERIAL NUMBER 1318242, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV 09-02308 WHA STIPULATION TO CONTINUE STAY AND PROPOSED ORDER 20 21 22 Plaintiff, United States of America, and Claimant Gary Hardeman respectfully submit this Stipulation to Continue the Stay of the instant civil forfeiture action. 23 On January 5, 2011, Court stayed the instant civil forfeiture case until April 7, 2011, due 24 to claimant’s pending criminal prosecution: United States v. Hardeman, 10-CR-00859 RS. That 25 stay was continued until September 1, 2011. As Mr. Hardeman’s criminal case is still ongoing, 26 and is scheduled for trial on November 14, 2011, the parties respectfully request an additional 27 stay of this case, so as not to raise the risk of self-incrimination or adversely affect the ability of 28 the government to prosecute the related criminal case. 1 2 For the aforementioned reasons, the parties respectfully request that the current case be stayed for 120 days. 3 4 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 5 6 7 8 9 10 11 [PROPOSED] ORDER TO STAY 12 13 14 15 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. 16 December 15, 2011 § 981(g) until ____________________. A further case management conference is scheduled for 17 December 15, 2011 at 11 a.m. December 15, 2011 at 11 a.m. ______________________________________. 18 19 SO ORDERED. 20 21 22 Dated: September 12, 2011 WILLIAM H. ALSUP United States District Judge 23 24 25 26 27 28 STIPULATION TO CONTINUE STAY AND PROPOSED ORDER No. CV 09-02308 WHA 2

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