UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al

Filing 15

Consent MOTION for Extension of Time to File Responsive Pleading by GOLDEN PANDA AD BUILDER, CLARENCE BUSBY, JR (Attachments: # 1 Text of Proposed Order)(Emord, Jonathan)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA, c/o United States Attorney's Office 555 Fourth St., N.W., Washington, D.C. 20530, Plaintiff, v. 8 GILCREASE LANE, QUINCY FLORIDA 32351, and, ONE CONDO LOCATED ON NORTH OCEAN BOULEVARD IN MYRTLE BEACH, SOUTH CAROLINA, and, ALL FUNDS, INCLUDING APPROXIMATELY $53 MILLION, HELD ON DEPOSIT AT BANK OF AMERICA ACCOUNTS IN THE NAMES (1) THOMAS A. BOWDOIN, JR., SOLE PROPRIETOR, DBA ADSURFDAILY, (2) CLARENCE BUSBY JR. AND DAWN STOWERS, DBA GOLDEN PANDA AD BUILDER, AND (3) GOLDEN PANDA AD BUILDER, Defendants, and GOLDEN PANDA AD BUILDER, AND CLARENCE BUSBY, JR. Claimants. UNNAPPOSED MOTION FOR EXTENSION TO FILE RESPONSIVE PLEADING Civil Action No: 1:08-cv-01345 Hon. Rosemary M. Collyer

CLAIMANT'S UNNAPPOSED MOTION FOR EXTENSION TO FILE RESPONSIVE PLEADING Clarence Busby Jr. d/b/a Golden Panda Ad Builder ("Golden Panda"), by counsel, hereby moves this Honorable Court for a 30-day extension to file responsive pleadings. 18 U.S.C. § 983(a)(4)(B) requires that a claimant file responsive pleadings within 20 days after submitting a claim to seized property. See also Fed. R. Civ. Pro Supplemental Rule G(5)(b). The Government filed its complaint against Golden Panda's property on August 5, 2008. Golden Panda timely filed its claim thereafter on August 22, 2008. See 18 U.S.C. § 983(a)(4)(A) (claims are timely filed within 30 days from date of complaint). Golden Panda has conferred with Government counsel concerning this motion. The Government has consented to a 30-day extension permitting Golden Panda to file its responsive pleadings by October 13, 2008.

Respectfully submitted, CLARENCE BUSBY JR. AND GOLDEN PANDA AD BUILDER By: ___________/s/_________________ Jonathan W. Emord* Andrea G. Ferrenz Peter A. Arhangelsky Emord & Associates, P.C. 11808 Wolf Run Lane Clifton, VA 20124 Ph: [phone] Fx: [phone] Its Counsel * Counsel of Record

D. Jack Smith Law Offices of D. Jack Smith 4620 Shady Grove Rd., Memphis, TN 39117 Co-Counsel

2