The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
JOINT STATUS REPORT, REQUEST FOR FURTHER STAY, AND PROPOSED ORDER
Plaintiff, United States of America, by and through its undersigned attorney, and claimant herein Manh Saechao, by and through her attorney, Danny D. Brace, Jr., (collectively, the "Parties") submit the following Joint Status Report, Request for Further Stay, and Proposed Order, pursuant to the Order filed by the Court in this action on November 25, 2009.
a) Status of service of process on parties not yet served:
All known potential claimants have been served with the Complaint for Forfeiture In Rem, Notice of Complaint, Application and Order for Publication, and Court Notices. Accordingly, service is complete. On March 15, 2009, Manh Saechao ("Claimant" or "Saechao") filed a Claim to the defendant property and an Answer to the Complaint for Forfeiture In Rem. On March 26, 2009, the clerk's entry of default was filed as to Juan Gabriel Alvarez and Victor Alvarez. On May 6, 2009, Saechao filed an Amended Claim.
In addition, notice of the forfeiture was published for 30 consecutive days on the official government Internet site (www.forfeiture.gov) commencing on January 26, 2009, in accordance with the Court's Order for Publication, as filed on January 23, 2009. Proof of Publication has been filed with the Court.
b) Possible joinder of additional parties: None anticipated at this time.
c) Anticipated amendment of pleadings: None anticipated at this time.
d) The basis for jurisdiction and venue:
The Court has jurisdiction in this matter pursuant to 28 U.S.C. § 1345 and 28 U.S.C. § 1355. Venue is proper in this district pursuant to 28 U.S.C. § 1355(b), 28 U.S.C. § 1395(b), and 21 U.S.C. § 881(j).
e) Anticipated motions with suggested dates:
The Parties request a further stay of this action pending the related criminal prosecution.
f) Anticipated and outstanding discovery:
The Parties request that this case not be scheduled at this time because they are requesting a further stay of proceedings for six months.
g) A written report outlining the proposed discovery plan required by Federal Rule of Civil Procedure 26(f). The discovery plan shall indicate the ...