STIPULATION TO CONTINUE DISCOVERY, MOTION, AND ANCILLARY HEARING DATES; ORDER THEREON
The United States of America and Petitioner Joseph R. Titland, by and through their undersigned attorneys, hereby stipulate:
1. This stipulation is executed by all parties who have appeared in and are affected by this action.
2. Subject to the Court's approval, the United States and Petitioner Titland propose to continue dates currently set for Discovery Cutoff (April 10); Dispositive Motions Cutoff (May 1) and the Ancillary Hearing Date (June 4, 2013), to June 15, July 15, and August 27, 2013, respectively, in order to allow the parties to coordinate this case's litigation schedule with a related civil in rem forfeiture involving the same exact parties, same forfeiture theory and same fact witnesses. The civil in rem forfeiture case, Case 2:09-cv-03085-LKK-EFB, also involves the forfeiture of property in Nevada City that is alleged to have been involved in criminal defendant Charles Hilkey's marijuana trafficking. The parties are set to file a joint status report in the civil in rem case on May 6, 2013.
3. The proposed continuances are further necessary in light of the parties' need to obtain current appraisals of both defendant properties, which have been ordered and should be completed in the very near future. New appraisals were required because the original appraisals were done in 2009 and do not reflect the current market value of the properties, thus severely hindering the parties' efforts to resolve this matter without the need for a lengthy evidentiary hearing.
4. The proposed litigation schedule:
Event Old Dates New Dates Discovery Cutoff April 10, 2013 June 15, 2013 Last Day to File Dispositive Motions May 1, 2013 July 15, 2013 Ancillary Hearing June 4, 2013 at 9:15 am August 27, 2013 at 9:15 am Dated: 4/2/13 BENJAMIN B. WAGNER United States Attorney By: /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney Dated: 4/2/13 /s/ Richard J. Troberman RICHARD J. TROBERMAN Counsel for Petitioner Joseph Titland (Authorized via email 4/2/13)
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