Cromwell et al v. United States Of America

Filing 28

STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER (Stipulation to Continue Hearing and Briefing and CMC) filed by United States Of America, Set/Reset Deadlines as to 27 STIPULATION WITH PROPOSED ORDER (Stipulation to Continue Hearing and Briefing), 14 Amended MOTION for Return of Property with Exhibits. Responses due by 8/1/2013. Replies due by 8/8/2013. Motion Hearing set for 8/22/2013 01:30 PM in Courtroom 5, 17th Floor, San Francisco befor e Hon. Edward M. Chen. Case Management Statement due by 9/12/2013. Further Case Management Conference set for 9/19/2013 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge EDWARD M. CHEN on 5/30/13. (bpf, COURT STAFF) (Filed on 5/30/2013)

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MELINDA HAAG (CABN 132612)
United States Attorney

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MIRANDA KANE (CABN 150630)
Chief, Criminal Division

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DAVID B. COUNTRYMAN (CSBN 226995)
Assistant United States Attorney

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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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JOHN EATON CROMWELL, Jr., et al., )
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Plaintiffs, )
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v.
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UNITED STATES OF AMERICA,
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Defendant. )
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No. CV 13-00519 EMC
STIPULATION TO CONTINUE
HEARING AND BRIEFING

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Due to unavailability of counsel (plaintiffs’ counsel is preparing for a capital murder trial

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in Orange County) and due to the anticipated release of funds held in the possession of Humboldt

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County to Elisabeth Nergaard Olsen and John Eaton Cromwell Jr. (“claimants”), which may have

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a bearing on the instant case, IT IS HEREBY STIPULATED by and between defendant United

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States of America and claimants, through undersigned counsel, that the hearing on the Motion for

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Return of Property and the defendant’s answer, be continued until August 22, 2013, or the

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earliest available date thereafter. It is further STIPULATED that the opposition to the Motion for

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Return of Property be continued to August 1, 2013, and the reply be continued until August 8,

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2013.

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Dated: 5/28/13
___/s/______________________________
DAVID M. MICHAEL
Attorney for Claimants
Elisabeth Nergaard Olsen and John Eaton Cromwell Jr.

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Dated: 5/28/13

___/s/________________________________
DAVID B. COUNTRYMAN
Assistant United States Attorney

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[PROPOSED] ORDER
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UPON CONSIDERATION of the parties' request, the entire record, and for good
30th
May
cause shown, it is by the Court on this ___________ day of ________, 2013, ORDERED that the

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case management conference is rescheduled to September 19, 2013 at 10:30 a.m. An
update joint CMC statement shall be filed by September 12, 2013.

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5/30/13

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Dated:

S DISTRICT
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C
TA
_______________________________

STIPULATION TO CONTINUE
CV 13-00519 EMC

D
RDERE
S SO O IED
IT I
DIF
AS MO
ard M
dge Edw

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UNIT
ED

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NO

HONORABLE EDWARD M. CHEN
United States District Judge

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Ju

. Chen
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R NIA

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FO

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August 1
the opposition to the Motion for Return of Property be continued to _______________________,
August 8
The further
2013, and the reply be continued until ________________________, 2013.

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hearing on the Motion for Return of Property and the defendant’s answer in the instant case be,
August 22
1:30 p.m.
and hereby is, CONTINUED until_______________________, 2013, at _________________,

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