STIPULATION FOR EXTENSION OF STAY OF FURTHER PROCEEDINGS AND PROPOSED ORDER
The United States and Claimants Damrong Pattanumotana, Darrin Pattanumotana, Gavin Pattanumotana, Goon Pattanumotana, Somluck Pattanumotana, and the Pattanumotana Family Limited Partnership (collectively the "claimants"), by and through their respective counsel, hereby submit the following Request for Extension of Stay of Further Proceedings and Proposed Order:
This matter was stayed on March 15, 2012 pending the outcome of criminal cases against several individuals charged with cultivating marijuana in violation of federal law at the defendant properties, United States v. Douangchanh Keovilayvanh, 1:10-CR-00476-LJO and United States v. Bouasangouane, et al., 1:11-CR-00357-AWI. None of the claimants have been charged with violations of the federal Controlled Substances Act.
The parties understand that a motion schedule and trial date have been set in United States v. Bouasangouane, et al., 1:11-CR-00357-AWI; the motions hearing is scheduled for June 3, 2013 and a Jury Trial is set for June 18, 2013. For this reason, the parties request that the stay be extended for a period of three months to June 3, 2013. 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.
Respectfully submitted, Dated: March 1, 2013 BENJAMIN B. WAGNER United States Attorney /s/ Kevin C. Khasigian d KEVIN C. KHASIGIAN Assistant United States Attorney Dated: March 1, 2013 /s/ Stephanie Hamilton Borchers d DONALD R. FISCHBACH STEPHANIE HAMILTON BORCHERS MATTHEW T. BESMER Attorneys for Claimants Darrin Pattanumotana, Damrong Pattanumotana, Gavin Pattanumotana, Goon Pattanumotana, Somluck Pattanumotana, and the Pattanumotana Family Limited Partnership (Original signature retained by attorney)
For the reasons set forth above, this matter is stayed for three months. On or before June 3, 2013, the parties will advise the Court whether a further stay is necessary.
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