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United States of America v. Approximately $18

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


March 12, 2013

UNITED STATES OF AMERICA, PLAINTIFF,
v.
APPROXIMATELY $18,220.00 IN U.S. CURRENCY,
DEFENDANT,

The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge

STIPULATION FOR EXTENSION OF STAY OF FURTHER PROCEEDINGS AND ORDER Date: April 15, 2013 Time: 9:00 a.m. Courtroom: 10

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), February 8, 2012 (Doc. 39), March 16, 2012 (Doc. 41), May 10, 2012 (Doc. 43), July 12, 2012 (Doc.

45), September 17, 2012 (Doc. 47), November 20, 2012 (Doc. 49), and again on January 14, 2013, 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 19, 2013. 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: 3/8/2013 BENJAMIN B. WAGNER United States Attorney /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney Dated: 3/11/2013 /s/ Danny D. Brace, Jr. DANNY D. BRACE, JR. Attorney for Claimant Manh Saechao (Signature authorized by email)

ORDER

For the reasons set forth above, this matter is stayed for an additional 60 days. On or before May 14, 2013, the parties will advise the Court whether a further stay is necessary.

The pretrial scheduling conference scheduled for April 15, 2013, is vacated and is rescheduled for June 24, 2013, at 9:00 a.m. A joint status report shall be filed fourteen days prior to the hearing.

20130312

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