United States of America v. $32,000.00 in United States Currency

Filing 1

First UNOPPOSED MOTION Extension of Time to File Civil In Rem Complaint by Plaintiff United States of America. Motion ripe 3/2/2012. (Attachments: # 1 Civil Cover Sheet)(Humphreys, Michael)

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DANIEL G. BOGDEN
United States Attorney
Nevada State Bar No. 2137
MICHAEL A. HUMPHREYS
Assistant United States Attorney
Lloyd D. George United States Courthouse
333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
E–Mail: [e-mail]
Attorneys for the United States

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
UNITED STATES OF AMERICA,

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Plaintiff,
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v.
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$32,000.00 IN UNITED STATES CURRENCY, )
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Defendant.
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Case No.:

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UNITED STATES’ UNOPPOSED APPLICATION TO
CONTINUE THE CAFRA DEADLINE
FOR THE UNITED STATES TO FILE ITS COMPLAINT

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The United States of America (“United States”), by and through Daniel G. Bogden, United

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States Attorney for the District of Nevada and Michael A. Humphreys, Assistant United States

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Attorney, respectfully moves this Court to grant an extension of time, until and including May 4,

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2012, for the United States to file its complaint in the above-captioned matter. The CAFRA deadline

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for the United States is March 5, 2012.

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Under CAFRA, the United States is obliged to file its Complaint for Forfeiture within 90

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days of receiving a referral from the agency that has received an administrative claim.18 U.S.C.

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983(a)(3)(A). That same section allows the 90-day deadline to be extended by stipulation of the

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parties as authorized by the court.

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In this case, the Government continues to investigate this matter to ascertain the basis for

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seizure that has led to the filing of an administrative claim by Justin Johnson. Such investigation

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will likely be concluded within the next 60 days, whereupon the United States will make a decision

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about whether to proceed with the judicial process in this matter.

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Government counsel discussed the matter of a government continuance with Claimant’s

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counsel, Tammy Riggs, on February 29, 2012, and Attorney Riggs gave Government counsel

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authorization to represent to this Court that she consents to this motion.

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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 its application to extend the time

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for the United States to file its Complaint for Forfeiture in this matter for an additional 60 days, or

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until May 4, 2012.

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DATED this 2nd day of March, 2012.

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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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UNITED STATES DISTRICT JUDGE

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DATED:

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