United States of America v. $1,002,327.00 in United States Currency et al

Filing 99

ORDER Granting 96 Motion to Continue the Discovery. Discovery due by 9/15/2015. Signed by Magistrate Judge George Foley, Jr on 6/15/2015. (Copies have been distributed pursuant to the NEF - DC)

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1 2 DANIEL G. BOGDEN United States Attorney District of Nevada 6 MICHAEL A. HUMPHREYS Assistant United States Attorney 333 Las Vegas Boulevard South, Suite 5000 Las Vegas, Nevada 89101 Telephone: 702-388-6336 Facsimile: 702-388-6787 Email: michael.humphreys@usdoj.gov 7 Attorneys for the United States of America. 3 4 5 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 UNITED STATES OF AMERICA, Plaintiff, 12 13 14 15 v. $1,002,327.00 IN UNITED STATES CURRENCY, et. al., Defendants. ) ) ) Case Nos: 2:13-CV-00100-(APG)-(CWH) ) And ) 2:13-CV-00947-(JCM)-(GWF) ) ) ) ) ) 16 17 18 PARTIES STIPULTED MOTION TO CONTINUE THE DISCOVERY COME NOW the parties, the plaintiff United States of America, by and through the United 19 States Attorney for the District of Nevada, and the Claimants by and through their attorneys David 20 McGee and Gregory Miller, and moves this Court to grant a continuance of discovery in the above- 21 referenced matters for 90 days, or until September 15, 2015. Discovery cut-off in these cases is June 15, 22 2015. For their grounds, the parties jointly represent that they have been engaged in “paper” and 23 deposition discovery to date. Currently the parties are engaged in discovery disputes that are under 24 consideration by this Court. Once those disputes have been resolved, discovery can resume. Resolution 25 of those discovery issues is not likely to occur before the discovery cut-off of June 15, 2015. 26 1 1 On June 9, 2015, Counsel for the Claimants, David McGee, sent an e-mail to the undersigned 2 counsel for the Government, giving his (Mr. McGee’s) consent on behalf of the Claimants to continue 3 the discovery cut-off deadline for an additional 90 days or until September 15, 2015. 4 This motion is not submitted solely for the purpose to delay or for any other improper purpose. 5 WHEREFORE, the United States moves this Court to grant a 90-day continuance, or until 6 September 15, 2015, to complete discovery. 7 DATED this 12th day of June 2015. 8 Respectfully submitted, 9 10 11 DANIEL G. BOGDEN United States Attorney /s/Michael A. Humphreys MICHAEL A. HUMPHREYS 12 13 14 15 IT IS SO ORDERED: 16 17 UNITED STATES MAGISTRATE JUDGE June 15, 2015 DATED: 18 19 20 21 22 23 24 25 26 2 PROOF OF SERVICE 1 2 I, Mary Stolz, Forfeiture Support Associates Paralegal, certify that the following individuals 3 were served with copies of the PARTIES STIPULTED MOTION TO CONTINUE THE DISCOVERY 4 on May 19, 2015, by the below identified method of service: 5 Via CM/ECF 6 David L. McGee Beggs & Lane, RLLP 501 Commendencia Street Pensacola, FL 32502 dlm@beggslane.com Counsel for claimants Charles Burton Ritchie, Stephanie Ritchie, Benjamin E. Galecki, and ZIW, LLC 7 8 9 10 11 12 13 Craig S. Denney Snell & Wilmer LLP 50 W. Liberty St., Ste. 510 Reno, NV 89501 cdenney@swlaw.com Counsel for claimants Charles Burton Ritchie, Stephanie Ritchie, Benjamin E. Galecki, and ZIW, LLC 14 15 16 /s/ Mary Stolz MARY STOLZ Forfeiture Support Associates Paralegal 17 18 19 20 21 22 23 24 25 26 3

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