United States of America v. $3,734.00 In United States Currency

Filing 2

ORDER Granting 1 Unopposed Motion to Extend CAFRA Deadline to file Civil Forfeiture Complaint against $3,734.00 in United States Currency until 5/30/2014. Signed by Chief Judge Gloria M. Navarro on 4/16/2014. (Copies have been distributed pursuant to the NEF - SLD)

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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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

14 UNITED STATES OF AMERICA,
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Plaintiff,
v.

17 $3,734.00 IN UNITED STATES
CURRENCY,
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Defendant.
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) Case No. 2:14-CV-564
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UNITED STATES’ UNOPPOSED MOTION TO EXTEND
CAFRA DEADLINE TO FILE CIVIL FORFEITURE COMPLAINT

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

23 the District of Nevada and Michael A. Humphreys, Assistant United States Attorney, respectfully
24 moves this Court to grant a forty-five day continuance, or until May 30, 2014, for the United States
25 to file its complaint for forfeiture in the above-captioned matter. Currently, the CAFRA deadline for
26 the United States to file its complaint is April 14, 2014.

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The reason for the requested extension of time is that the United States is still evaluating the

2 merits of the case and deciding whether it should proceed by way of civil forfeiture proceedings or
3 criminal forfeiture proceedings against the seized assets.
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On Friday, April 11, 2014, Government counsel spoke by telephone with Osvaldo Fumo,

5 Claimant’s counsel, and Attorney Fumo gave his consent for Government counsel to communicate
6 to this Court that he has no objection to the Government’s request for a continuance in this matter.
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This motion is not submitted solely for the purpose to delay or for any other improper

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WHEREFORE, the United States moves this Court to grant a forty-five day continuance, or

10 until May 30, 2014, for the United States to file its civil forfeiture complaint and/or incorporate the
11 forfeiture in a criminal charging document.
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DATED this 14th 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

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IT IS SO ORDERED.

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IT IS SO ORDERED:

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_____________________________ JUDGE
UNITED STATES MAGISTRATE
Gloria M. Navarro, Chief Judge
DATED:
United States District Court

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DATED: 04/16/2014

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CERTIFICATE OF SERVICE
I, Ray Southwick, Forfeiture Support Associates Paralega, hereby certify that service of the

3 foregoing UNITED STATES’ UNOPPOSED MOTION TO EXTEND CAFRA DEADLINE
4 TO FILE CIVIL FORFEITURE COMPLAINT was made by sending a copy of same by first
5 class mail, addressed to Claimant’s counsel, Osvaldo Fumo, on this 14th day of April, 2014:
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Osvaldo Fumo
1212 Casino Center Boulevard
Las Vegas, NV 89104

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/s/ Ray Southwick
RAY SOUTHWICK
Forfeiture Support Associates Paralegal

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