Date: April 23, 2012 Time: 9:00 a.m. Courtroom: 10
STIPULATION FOR EXTENSION OF STAY OF FURTHER PROCEEDINGS AND ORDER (PROPOSED)
The United States of America and claimant Manh Saechao (hereafter "claimant") submit the following Request for Extension of Stay of Further Proceedings and Proposed Order.
This matter was stayed on May 22, 2009 (Doc. 18), November 25, 2009 (Doc. 20), June 8, 2010 (Doc. 22), November 12, 2010 (Doc. 25), February 3, 2011 (Doc. 29), May 23, 2011 (Doc. 33), August 2, 2011 (Doc. 35), November 28, 2011 (Doc. 37), and again on February 8, 2012 (Doc. 39) because of the pending related criminal cases against Juan Gabriel Alvarez in U.S. v. Reyes, No. 2:08-CR-00392-GEB and U.S. v. Aguilar-Godinez, No. 2:08-CR-00570-GEB. The parties understand that sentencing of Juan Gabriel Alvarez in the criminal cases is presently scheduled for April 27, 2012. For this reason, the parties request that the stay be extended for an additional 60 days.
At that time, the parties will advise the court of the status of the criminal cases and will advise the court whether a further stay is necessary.
Dated: 03/13/2012 BENJAMIN B. WAGNER United States Attorney /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney Dated: 3-13-12 /s/Danny D. Brace, Jr. DANNY D. BRACE, JR. Attorney for Claimant Manh Saechao (Signature retained by attorney)
For the reasons set forth above, this matter is stayed for an additional 60 days. On or before May 15, 2012, the parties will advise the Court whether a further stay is necessary.
The pretrial scheduling conference scheduled for April 23, 2012, is vacated and is rescheduled for June 25, 2012. A joint status report shall be filed fourteen days prior to the hearing.
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