United States of America v. Approximately $118,820 and $34,000 in United States Currency

Filing 25

STIPULATION AND ORDER RESETTING CMC TO 6/1/11 re 24 Status Report filed by United States of America. Signed by Judge Edward M. Chen on 3/16/11. (bpf, COURT STAFF) (Filed on 3/16/2011)

United States of America v. Approximately $118,820 and $34,000 in United States Currency

Doc. 25

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MELINDA HAAG (CSBN 132612) United States Attorney MIRANDA KANE (CSBN 150630) Chief, Criminal Division NATALIE WIGHT (ORBN 35576) Assistant United States Attorney 450 Golden Gate Avenue, 11th Floor San Francisco, CA 94102 Telephone: [phone] Facsimile: 415.436.7234 Email: [e-mail] Attorneys for United States of America JOSEPH D. ELFORD (CSBN 189934) 1322 Webster Street, Suite 402 Oakland, CA 94612 Telephone: [phone] Facsimile: 510.251.2036 Email: [e-mail] Attorney for Claimant, Ciciriello UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) APPROXIMATELY $118,820 IN UNITED ) STATES CURRENCY AND $34,000 IN ) UNITED STATES CURRENCY, ) ) Defendants, ) ) ) Gary Ciciriello ) ) Claimant, ) ) 09-CV-03963-EMC

JOINT STATUS REPORT AND [PROPOSED] ORDER TO CONTINUE STAY AND RESCHEDULE CMC

The plaintiff United States of America and claimant Gary Ciciriello, through undersigned counsel, hereby request to continue the Stay of the civil forfeiture proceedings, as ordered by the Court on April 20, 2010. The related criminal action, California v. Gary Ciciriello, Docket

Dockets.Justia.com

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Number 10007444 (Superior Court of San Francisco County), is still pending with a trial date set for May 6, 2011. Accordingly, the parties request that the Court vacate the Case Management Conference currently scheduled for March 16, 2011, at 1:30 p.m., and reschedule the Case Management Conference for May 25, 2011, at 1:30 p.m. or as soon thereafter as the matter may be heard by the Court.

IT IS SO STIPULATED.

MELINDA HAAG United States Attorney

Dated: March 14, 2011

/S/ NATALIE K. WIGHT Assistant United States Attorney /S/ JOSEPH D. ELFORD Attorney for Claimant, Gary Ciciriello

Dated: March 14, 2011

[PROPOSED] ORDER Pursuant to the Stipulation between the parties and for good cause shown, the Case Management Conference scheduled for Wednesday March 16, 2011, is hereby vacated. The June 1, 2011 at 1:30 p.m. Case Management Conference is rescheduled for_________________________________; May 25, 2011 with a Joint Status Report due to the Court by _____________________________________.

IT IS SO ORDERED.

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Joint Status Report and [Proposed] Order to Continue Stay No. CV 09-CV-03963-EMC 2

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