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

Filing 81

Consent MOTION for Extension of Time to File Response/Reply by THOMAS A. BOWDOIN, JR, BOWDOIN HARRIS ENTERPRISES, INC., ADSURFDAILY, INC. (Attachments: # 1 Text of Proposed Order)(Murray, Charles) Modified on 8/4/2009 to add Claimant(rdj).

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UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al Doc. 81 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) 8 GILCREASE LANE, QUINCY ) FLORIDA 32351, ET AL., ) ) Defendants. ) ______________________________/ Civil No. 08-1345 (RMC) CONSENT MOTION FOR EXTENSION OF TIME TO RESPOND TO ORDER TO SHOW CAUSE CONSENT MOTION FOR EXTENSION OF TIME TO RESPOND TO ORDER TO SHOW CAUSE Thomas A. Bowdoin, Jr. and AdSurfDaily ("ASD") (collectively, the "Claimants"), by counsel, hereby submit this consent motion for an extension of time beyond the present due date of August 7, 2009, until August 28, 2009, for the submission of Bowdoin and ASD's response to this Court's July 24, 2009 Order to Show Cause. Counsel for the Claimants has entered into negotiations with Government counsel that could result in an agreement resolving the matters in dispute either in part or whole. Government counsel has been informed of this motion and consents to it. See LCvR 7(m) (duty to confer). Good cause exists for the granting of the motion because the 21 day extension will not be to the prejudice of the Court or the parties, may avoid the need for this Court to address the matters raised in the Order to Show Cause, and may facilitate an agreed to resolution of the matters in dispute either in part or whole. Dated: August 3, 2009 Respectfully submitted, By: __________________________ Charles A. Murray, Esq. 27911 Crown Lake Blvd., Suite 223 Bonita Springs, FL 34135-4218 239-649-7773 Voice / 239-262-3517 Fax Email: charles@camurraylaw.com Dockets.Justia.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing has been furnished via, email, fax and regular First Class U.S. Mail to William R. Cowden and Jeffrey A. Taylor, Assistant United States Attorneys, Asset Forfeiture Unit, 555 4th Street N.W. Washington, DC 20530 this 3rd day of August, 2009. Charles A. Murray, Esq. Attorney for the Claimants Thomas A. Bowdoin, Jr. and AdSurfDaily

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