United States of America v. 1975 Grumman American G-1159 et al

Filing 10

ORDER Granting 9 Motion to Extend CAFRA Deadline to File Complaint. Complaint due by 5/2/2014. Signed by Magistrate Judge Carl W. Hoffman on 4/29/14. (Copies have been distributed pursuant to the NEF - MMM)

1 DANIEL G. BOGDEN
United States Attorney
2 District of Nevada
3 MICHAEL A. HUMPHREYS
Assistant United States Attorney
4 333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
5 Telephone: [phone]
Facsimile: 702-388-6787
6 Email: [e-mail]
7 Attorneys for the United States of America
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9

UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

11 UNITED STATES OF AMERICA,
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Plaintiff,
v.

14 1975 GRUMMAN AMERICAN G-1159
AIRPLANE, SERIAL NO. 157
15 TAIL REGISTRATION NO. N468HW,
16 1969 GRUMMAN AMERICAN G-1159
AIRPLANE, SERIAL NO. 50
17 TAIL REGISTRATION NO. N650KA,
18
Defendants.

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2:14-CV-101-APG-(CWH)

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UNITED STATES’ FIFTH MOTION TO
EXTEND CAFRA DEADLINE TO FILE COMPLAINT

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21

The United States of America by and through Daniel G. Bogden, United States Attorney for

22 the District of Nevada and Michael A. Humphreys, Assistant United States Attorney, respectfully
23 moves this Court to grant a five day extension, or until May 2, 2014, to file its forfeiture complaint,
24 in rem in the above-captioned action. The CAFRA deadline for the Government to file its complaint
25 is currently April 28, 2014. On April 21, 1014, this Court granted a brief continuance of this matter
26 until April 28, 2014.

1

For its grounds, the United States says that the parties to this action, the United States of

2 America, plaintiff, and the Claimant, Ford Electric, have reached a verbal agreement to settle the
3 case, but need an additional few days to allow the verifying agent to review the complaint and sign
4 the verification on behalf of the Government. All forfeiture complaints must be verified pursuant to
5 Fed. R. Civ. P, Supp. Rule G (2)(a). The verifying agent is located in Houston, Texas but will be out
6 of his Texas office until Wednesday April 30, 2014 and cannot verify the complaint before that date.
7 Once the agent verifies the forfeiture complaint, the complaint can be filed, as well as the settlement
8 stipulation, the terms of which, to date, all parties have agreed to. The parties will then present the
9 settlement stipulation to this Court for review and approval.
10

The undersigned has discussed this matter with Claimant’s counsel, Paul Padda, and he has

11 given Government counsel consent to inform this Court that he does not oppose this five-day
12 extension.
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WHEREFORE, the United States moves this Court to grant its motion to extend the time for

14 the United States to file its complaint in this matter for an additional five (5) days; or until May 2,
15 2014.
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DATED this 28th day of April 2014.

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Respectfully submitted,

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DANIEL G. BOGDEN
United States Attorney

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/s/Michael A. Humphreys
MICHAEL A. HUMPHREYS
Assistant United States Attorney

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IT IS SO ORDERED:
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24

UNITED STATES MAGISTRATE JUDGE

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DATED: April 29, 2014

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