United States of America v. $10,500.00

Filing 2

ORDER granting 1 Unopposed Motion to Continue CAFRA Deadline. Signed by Chief Judge Robert C. Jones on 3/21/2012. (Copies have been distributed pursuant to the NEF - DRM)

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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]
Attorney for the United States

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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Plaintiff,
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v.
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$10,500.00 IN UNITED STATES CURRENCY, )
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Defendant.
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UNITED STATES OF AMERICA,

Case No.:

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UNITED STATES’ UNOPPOSED MOTION 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 20,

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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 19, 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 Tarik Soodan. Such investigation will

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

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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, Scott Freeman, on March 14, 2012, and Attorney Freeman gave Government counsel

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authorization to represent to this Court that he 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 motion to extend the time for

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

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May 20, 2012.

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DATED this 15th day of March, 2012.

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Respectfully submitted,
DANIEL G. BOGDEN
United States Attorney

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/s/Michael A. Humphreys
MICHAEL A. HUMPHREYS
IT IS SO ORDERED: March 21, 2012

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UNITED STATES DISTRICT JUDGE

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