United States of America v. $1,002,327.00 in United States Currency et al
Filing
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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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DANIEL G. BOGDEN
United States Attorney
District of Nevada
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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
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Attorneys for the United States of America.
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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UNITED STATES OF AMERICA,
Plaintiff,
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v.
$1,002,327.00 IN UNITED STATES
CURRENCY, et. al.,
Defendants.
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) Case Nos: 2:13-CV-00100-(APG)-(CWH)
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And
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2:13-CV-00947-(JCM)-(GWF)
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PARTIES STIPULTED MOTION TO CONTINUE THE DISCOVERY
COME NOW the parties, the plaintiff United States of America, by and through the United
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States Attorney for the District of Nevada, and the Claimants by and through their attorneys David
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McGee and Gregory Miller, and moves this Court to grant a continuance of discovery in the above-
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referenced matters for 90 days, or until September 15, 2015. Discovery cut-off in these cases is June 15,
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2015. For their grounds, the parties jointly represent that they have been engaged in “paper” and
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deposition discovery to date. Currently the parties are engaged in discovery disputes that are under
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consideration by this Court. Once those disputes have been resolved, discovery can resume. Resolution
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of those discovery issues is not likely to occur before the discovery cut-off of June 15, 2015.
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On June 9, 2015, Counsel for the Claimants, David McGee, sent an e-mail to the undersigned
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counsel for the Government, giving his (Mr. McGee’s) consent on behalf of the Claimants to continue
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the discovery cut-off deadline for an additional 90 days or until September 15, 2015.
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This motion is not submitted solely for the purpose to delay or for any other improper purpose.
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WHEREFORE, the United States moves this Court to grant a 90-day continuance, or until
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September 15, 2015, to complete discovery.
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DATED this 12th day of June 2015.
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Respectfully submitted,
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DANIEL G. BOGDEN
United States Attorney
/s/Michael A. Humphreys
MICHAEL A. HUMPHREYS
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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
June 15, 2015
DATED:
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PROOF OF SERVICE
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I, Mary Stolz, Forfeiture Support Associates Paralegal, certify that the following individuals
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were served with copies of the PARTIES STIPULTED MOTION TO CONTINUE THE DISCOVERY
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on May 19, 2015, by the below identified method of service:
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Via CM/ECF
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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
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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
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/s/ Mary Stolz
MARY STOLZ
Forfeiture Support Associates Paralegal
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