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United States of America v. Approximately $18

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


May 14, 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. United States District Judge

STIPULATION FOR EXTENSION OF STAY OF FURTHER PROCEEDINGS AND ORDER (PROPOSED) Date: June 24, 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), January 14, 2013, (Doc. 49) and again on March 13, 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 July 19, 2013. For this reason, the parties request that the stay be extended for an additional 90 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: 5/14/2013 BENJAMIN B. WAGNER United States Attorney /s/ Kevin C. Khasigian KEVIN C. KHASIGIAN Assistant U.S. Attorney Dated: 5-14-13 /s/ Danny D. Brace, Jr. DANNY D. BRACE, JR. Attorney for Claimant Manh Saechao (Signature retained by attorney)

ORDER

For the reasons set forth above, this matter is stayed for an additional 90 days. On or before August 12, 2013, the parties will advise the Court whether a further stay is necessary.

The pretrial scheduling conference scheduled for June 24, 2013, is vacated and is rescheduled for September 16, 2013, at 9:00 a.m. A joint status report shall be filed fourteen days prior to the hearing.

IT IS SO ORDERED.

20130514

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