United States of America v. One Hewlett Packard Pavilion Laptop (Serial No. CNF75237NC), Adaptor, and Visual Depoicitions on the Hard Drive

Filing 16

ORDER GRANTING EXTENSION OF TIME TO RESPOND TO COMPLAINT [re 15 First MOTION for Extension of Time to File Answer by Stipulation filed by One Hewlett Packard Pavilion Laptop (Serial No. CNF75237NC), Adaptor, and Visual Depoicitions on the Hard Drive]. Signed by Judge William Alsup on 8/6/2009. (whasec, COURT STAFF) (Filed on 8/6/2009)

(SPACE BELOW FOR FILING STAMP ONLY)

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EDGAR EUGENE PAGE (231147) KATHLEEN C. PAGE (233040) PAGE & PAGE ATTORNEYS AT LAW Post Office Box 2837 San Francisco, California 94126-2837 Phone [phone] Fax [phone]

Attorneys for Defendant and Real Party in Interest

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO ******** UNITED STATES OF AMERICA, Plaintiffs, v. ONE HEWLETT PACKARD PAVILION LAPTOP (SERIAL NO. CNF75237NC), ADAPTOR, AND VISUAL DEPICTIONS ON THE HARD DRIVE, Defendants Case No.: 3:09-cv-2664-WHA

STIPULATED REQUEST TO EXTEND TIME TO FILE ANSWER TO THE COMPLAINT FOR FORFEITURE

18 19 20 21 TO: 22 23 Andrew Samuel Hanson, real party in interest, by and through his attorney, Edgar Eugene 24 Page, of Page & Page Attorneys at Law, requests to extend time for Mr. Hanson to file his 25 Answer to the Complaint for Forfeiture in the above-listed case. 26 The attached Declaration of Edgar Eugene Page supports this request. U.S.D.C., N.D. 27 Cal., L.R. 6-2(a). 28 THE HONORABLE JUDGE OF THE ABOVE-ENTITLED COURT, AND THE PLAINTIFFS, BY AND THROUGH THEIR COUNSEL, NATIALIE K. WIGHT, SPECIAL ASSISTANT UNITED STATE ATTORNEY. ANDREW S. HANSON, . Real Party in Interest

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DECLARATION OF EDGAR EUGENE PAGE I, EDGAR EUGENE PAGE, do hereby declare that: 1. 2. I am duly licensed to practice law in the State of California. I am a member in good standing in the State Bar of California, designated as member number 231147. I am permitted to practice law before the United States District Court, Northern District of California. I am permitted to practice law before the United States Circuit Court of Appeals for the Ninth Circuit. I am permitted to practice law before the Supreme Court of the United States. I represent Andrew Samuel Hanson, real party in interest, in the matter pending before this court, captioned as United States of America v. One Hewlett Packard Pavilion Laptop (Serial No. CNF75237NC), Adaptor, and Visual Depictions on the Hard Drive, designated as case number 3:09-cv-2664-WHA. Counsel miscalculated the day to file Mr. Hanson's Answer to the Complaint for Forfeiture; counsel believed that the due date was August 5, 2009, instead the due date was August 4, 2009. U.S.D.C., N.D. Cal., L.R. 6-2(a)(1). Counsel needs additional time to review the issued related to Mr. Hanson's exercising of his Fifth Amendment rights in any potentially related criminal proceedings. U.S.D.C., N.D. Cal., L.R. 6-2(a)(1). There have been no other time modifications in this case. U.S.D.C., N.D. Cal., L.R. 6-2(a)(2). The requested extension of time would have no effect on the schedule of this case. U.S.D.C., N.D. Cal., L.R. 6-2(a)(3). Counsel for Mr. Hanson contacted plaintiff's counsel, Natalie K. Wight, Special Assistant United States Attorney, on August 5, 2009, regarding Mr. Hanson's Answer to the Complaint for Forfeiture. Ms. Wight informed Mr. Page that the government consents to a two-week -2-

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extension, up to and including, August 18, 2009, to file the Answer to the Complaint for Forfeiture in the above-listed case. The foregoing are true and correct to the best of my knowledge and belief at the time of executing this declaration. EXECUTED under penalty of perjury under the laws of the United States of America, in San Francisco, California. Dated: August 5, 2009 Respectfully submitted, Page & Page Attorneys at Law /s/ Edgar Eugene Page Attorney for Andrew Hanson

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO ******** UNITED STATES OF AMERICA, Plaintiffs, Case No.: 3:09-cv-2664-WHA PROPOSED ORDER

ONE HEWLETT PACKARD PAVILION LAPTOP (SERIAL NO. CNF75237NC), ADAPTOR, AND VISUAL DEPICTIONS ON THE HARD DRIVE, Defendants

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ANDREW S. HANSON, . Real Party in Interest

PURSUANT TO STIPULATION, IT IS SO ORDERED, that the time for filing the Answer to the Complaint for Forfeiture in the above-listed case is extended August 18, 2009. Dated: __ugust___________ A ____ 6, 2009. ___________________________________ William H. Alsup, U.S. District Court Judge
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