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

Filing 4

ORDER Granting 3 Unopposed Motion to Extend re: Forfeiture Complaint. Complaint deadline: 6/30/2014. Signed by Chief Judge Gloria M. Navarro on 6/4/2014. (Copies have been distributed pursuant to the NEF - SLR)

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.
8
9
10
11

UNITED STATES DISTRICT COURT

12

DISTRICT OF NEVADA

13 UNITED STATES OF AMERICA,
14
15

Plaintiff,
v.

16 $3,734.00 IN UNITED STATES
CURRENCY,
17
Defendant.
18
19

)
)
)
)
) 2:14-CV-564-GMN-(PAL)
)
)
)
)
)

UNITED STATES’ SECOND UNOPPOSED MOTION TO EXTEND
CAFRA DEADLINE TO FILE CIVIL FORFEITURE COMPLAINT

20
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 thirty day continuance, or until June 30, 2014, for the United States to
24 file its complaint for forfeiture in the above-captioned matter. Currently, the CAFRA deadline for
25 the United States to file its complaint is May 30, 2014.
26 . . .

1

The reason for the requested extension of time is that the United States continues to evaluate

2 the merits of the case to decide whether it should proceed by way of civil forfeiture proceedings or
3 criminal forfeiture proceedings against the seized assets.
4

On Friday, May 30, 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 thirty-day continuance, or until

10 June 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 30th day of May 2014.

13
Respectfully submitted,
14
DANIEL G. BOGDEN
United States Attorney

15
16

/s/Michael A. Humphreys
MICHAEL A. HUMPHREYS

17
18
19

IT IS SO ORDERED:
IT IS SO ORDERED.

20
UNITED STATES MAGISTRATE JUDGE

21
22

_____________________________
DATED:
Gloria M. Navarro, Chief Judge
United States District Court

23
24

DATED: 06/04/2014

25
26
2

1

CERTIFICATE OF SERVICE

2

It is hereby certified that service of the foregoing UNITED STATES’ SECOND
UNOPPOSED MOTION TO CONTINUE THE CAFRA DEADLINE was made by sending a
3 copy of same by first class mail, addressed to Claimant’s counsel, Osvaldo Fumo, on this 30th day of
May, 2014:
4
Osvaldo Fumo
5
601 Las Vegas Blvd. S.
Las Vegas, NV 89109
6
7

/s/ Ray Southwick
Ray Southwick
Forfeiture Support Associates Paralegal

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
3