United States of America v. Real property located at 15438 Old Toll Road, Camptonville, California, APN: 064-210-041

Filing 35

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr. on 11/22/2011 MODIFYING 18 Status (Pretrial Scheduling) Order: Discovery due by 12/9/2011, Disclosure of Expert Witnesses due by 12/23/2011. (Michel, G)

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1 4 BENJAMIN B. WAGNER United States Attorney KEVIN C. KHASIGIAN Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 5 Attorneys for the United States 2 3 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE EASTERN DISTRICT OF CALIFORNIA 8 9 UNITED STATES OF AMERICA, 10 Plaintiff, 11 v. 12 15 REAL PROPERTY LOCATED AT 15438 OLD TOLL ROAD, CAMPTONVILLE, CALIFORNIA, YUBA COUNTY, APN: 064-210-041, INCLUDING ALL APPURTENANCES AND IMPROVEMENTS THERETO, 16 Defendant. 13 14 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 2:11-CV-00099-GEB-KJN STIPULATION TO CONTINUE SCHEDULING DATES AND ORDER THEREON (First Request) 17 Claimant Gregory S. McClellan and plaintiff United States of 18 America, by and through their undersigned attorneys, hereby 19 stipulate as follows: 20 1. This stipulation is executed by all parties who have 21 appeared in and are affected by this action. 22 2. The parties are requesting a brief extension of the 23 discovery dates set out in the Scheduling Conference Order due to 24 unavailability of counsel on said dates, to synchronize discovery 25 efforts in this case and the related case, United States v. Real 26 Property Located at 15340 Old Toll Road, Camtonville, California, 27 28 1 Stip and Order to Continue Scheduling Dates 1 Case No: 2:11-CV-00091-GEB-KJN.1 2 scheduling conference, counsel has been unavailable for 3 depositions and requires additional time to respond to discovery 4 due to pressing business on other cases. 5 coordinating the discovery schedules in the two related cases 6 reduces litigation expense and streamlines the discovery process. 7 This is the Parties’ first request for an extension. 8 /// 9 /// 10 /// 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// Since the time of the initial In addition, 24 1 25 26 27 28 Each civil forfeiture action originates from the same law enforcement investigation and action, a federal search warrant executed on September 16, 2010. See Doc. 1, 2:11-CV-00091-GEBKJN; Doc. 1, 2:11-CV-00099-GEB-KJN. The related cases proceed on dissimilar discovery tracks given the litigation on an unrelated issue. Gregory S. McClellan filed his claim in Case No. 2:11-CV00099-GEB-KJN on September 1, 2011. 2 Stip and Order to Continue Scheduling Dates 1 3. The following dates are agreed on by the parties: 2 Event 3 Non-Expert 4 Discovery 5 Deadline 6 Designation of 7 Expert Witnesses Existing Date Proposed Date November 1, 2011 December 9, 2011 November 22, 2011 December 23, 2011 8 9 Dated: 10/28/11 BENJAMIN B. WAGNER United States Attorney 10 11 By: /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney By: 12 /s/ Stephen A. Munkelt STEPHEN A. MUNKELT Attorney for Claimant Gregory S. McClellan 13 14 Dated: 10/28/11 15 16 17 (Original signatures retained by attorney) 18 19 20 21 ORDER IT IS SO ORDERED. 22 Dated: November 22, 2011 23 24 25 GARLAND E. BURRELL, JR. United States District Judge 26 27 28 3 Stip and Order to Continue Scheduling Dates

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