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

Filing 22

Consent MOTION for Extension of Time to File Response/Reply as to 18 Emergency MOTION for Release of Funds 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. 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.

Civil Action No: 1:08-cv-01345 Hon. Rosemary M. Collyer

CONSENT MOTION FOR EXTENSION OF TIME Claimants Golden Panda Ad Builder ("Golden Panda") and Clarence Busby, Jr., by counsel, hereby move this Court for a three-week extension of time to file its Reply to the Plaintiff's Opposition to Claimant's Motion for Release of Seized Funds. Golden Panda respectfully requests a 21-day extension, and a new deadline of October 8, 2008, to file its Reply.

Ongoing negotiations may render Golden Panda's Reply moot. Plaintiffs, through counsel, consent to the relief requested in this motion. For the foregoing reasons, claimant Golden Panda respectfully requests that this Honorable Court grant the requested extension.

Respectfully submitted, GOLDEN PANDA AD BUILDER,

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

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] [e-mail] Its Counsel * Counsel of Record

Date submitted: September 15, 2008

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