United States of America v. $209,815 in United States Currency

Filing 43

STIPULATION AND ORDER to Extend Time for Motion to Suppress Reply Brief. Signed by Judge Samuel Conti on 06/16/2014. (tmi, COURT STAFF) (Filed on 6/16/2014)

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1 2 3 4 5 6 7 8 DAVID M. MICHAEL, CSBN 74031 EDWARD M. BURCH, CSBN 255470 LAW OFFICES OF DAVID M. MICHAEL One Sansome Street, Suite 3500 San Francisco, CA 94104 Telephone: (415) 946-8996 Facsimile: (877) 538-6220 E-mail: david@davidmichaellaw.com Attorneys for Claimant JULIO FIGUEROA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 9 10 11 UNITED STATES OF AMERICA, No. 3:14-cv-00780-SC Plaintiff, 12 v. 13 14 15 16 STIPULATION TO EXTEND TIME FOR $209,815 IN UNITED STATES CURRENCY, MOTION TO SUPPRESS REPLY BRIEF NUNC PRO TUNC Defendant. ______________________________________/ 17 JULIO FIGUEROA, 18 Claimant. ______________________________________/ 19 20 21 The parties through their undersigned counsel agree, subject to the Court’s approval, that 22 Claimant may have up to and including June 13, 2014, to file his reply in support of his motion 23 to suppress. 24 The reply brief was due on or before June 10, 2014. The reason the Claimant has 25 requested counsel for Plaintiff to agree an extension for the filing deadline by three days is due to 26 unexpected increased case load, mainly regarding Claimant’s counsel’s ongoing murder 27 prosecution in Orange County, California, while co-counsel Burch was overseas on a long 28 planned vacation. Counsel for Plaintiff graciously agreed. Stipulation Extending Time for Repy Brief Re Motion to Suppress No. 3:14-cv-00780-SC 1 1 IT IS SO STIPULATED: 2 LAW OFFICES OF DAVID M. MICHAEL 3 4 Dated: 13 June 2014 s/Edward M. Burch DAVID M. MICHAEL EDWARD M. BURCH Attorneys for Claimant Julio Figueroa 5 6 7 8 MELINDA HAAG United States Attorney 9 10 Dated: 13 June 2014 11 s/Patricia J. Kenney PATRICIA J. KENNEY Assistant United States Attorney Attorneys for the United States 12 13 14 24 ER H 23 R NIA onti amuel C Judge S RT 22 NO 21 FO 20 THE HONORABLE SAMUEL CONTI United States District Judge LI 19 S DISTRICT TE C ______________________________________ TA RT U O 18 Dated: 6/16/2014 A 17 S 16 PURSUANT TO THE FOREGOING STIPULATION IT IS SO ORDERED. UNIT ED 15 N D IS T IC T R OF C 25 26 27 28 Stipulation Extending Time for Repy Brief Re Motion to Suppress No. 3:14-cv-00780-SC 2 1 2 3 4 5 6 CERTIFICATE OF ELECTRONIC SERVICE I hereby certify that, on 13 June 2014, I caused to be electronically filed the foregoing with the clerk of the court by using the CM/ECF system, which will send a notice of electronic filing on all ECF-registered counsel by operation of the Court’s electronic filing system. Parties may access this filing through the Court’s system. s/Edward M. Burch EDWARD M. BURCH Attorney for Claimant Julio Figueroa 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation Extending Time for Repy Brief Re Motion to Suppress No. 3:14-cv-00780-SC 3

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