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)

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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: 702-388-6336 Facsimile: 702-388-6787 6 Email: Michael.humphreys@usdoj.gov 7 Attorneys for the United States of America. 8 9 10 11 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 UNITED STATES OF AMERICA, 15 16 Plaintiff, v. 17 $3,734.00 IN UNITED STATES CURRENCY, 18 Defendant. 19 20 ) ) ) ) ) Case No. 2:14-CV-564 ) ) ) ) ) UNITED STATES’ UNOPPOSED MOTION TO EXTEND CAFRA DEADLINE TO FILE CIVIL FORFEITURE COMPLAINT 21 22 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. 1 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. 4 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. 7 This motion is not submitted solely for the purpose to delay or for any other improper 8 purpose. 9 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. 12 DATED this 14th day of April 2014. 13 Respectfully submitted, 14 DANIEL G. BOGDEN United States Attorney 15 16 /s/Michael A. Humphreys MICHAEL A. HUMPHREYS 17 18 IT IS SO ORDERED. 19 IT IS SO ORDERED: 20 _____________________________ JUDGE UNITED STATES MAGISTRATE Gloria M. Navarro, Chief Judge DATED: United States District Court 21 22 DATED: 04/16/2014 23 24 25 26 2 1 2 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: 6 7 Osvaldo Fumo 1212 Casino Center Boulevard Las Vegas, NV 89104 8 /s/ Ray Southwick RAY SOUTHWICK Forfeiture Support Associates Paralegal 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3

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