The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
STIPULATION TO EXTEND STAY OF FURTHER PROCEEDINGS AND ORDER THEREON [PROPOSED]
DATE: April 27, 2009 TIME: 9:00 a.m. COURT: 10
Plaintiff United States of America and claimant John Steve Lindsey, by and through their respective counsel, hereby stipulate that an extension of the stay previously entered in this case on January 7, 2009, is necessary in the above-entitled action, and request that the Court enter an order staying all further proceedings until June 15, 2009.
This request is based on the following:
1. On April 7, 2009, counsel for the government spoke with Butte County Deputy District Attorney Stacey Edwards. Ms. Edwards advised counsel that the following dates have been set in the prosecution of claimant herein, John Lindsey:
a. April 16, 2009: settlement conference.
b. May 20, 2009: readiness conference.
c. June 1, 2009: jury trial.
2. Ms. Edwards expects that this case will go to trial as scheduled, and that the trial will take approximately five court days. Assuming claimant Lindsey is convicted, he would be sentenced within 20 days unless he waives time.
3. Accordingly, the parties request that the status conference now scheduled for April 27, 2009, be continued to June 15, 2009. If the state prosecution has not concluded by that time, the parties will so advise the Court 14 days prior to the status conference and will request a further stay, if the parties deem such a further stay appropriate. If the case has concluded, the parties will submit a joint status (pretrial scheduling) report.
LAWRENCE G. BROWN Acting United States Attorney
KRISTIN S. DOOR Assistant U.S. Attorney Attorneys for plaintiff ...