Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cv-01910-EBB

Document 69

Filed 04/23/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : Plaintiff, : : v. : : $140,000.00 IN UNITED STATES : CURRENCY SEIZED FROM ACCOUNT : NUMBER 1215701749, HELD IN THE : NAME OF ARTHUR F. GRANT, : AT BANK OF AMERICA, : ROLLING HILLS, CALIFORNIA, : : Defendant. : : [CLAIMANT: ARTHUR F. GRANT] : UNITED STATES OF AMERICA,

Civil No. 3:00CV1910 (EBB)

April 23, 2007

SIXTH MOTION TO EXTEND SCHEDULING DEADLINES The Plaintiff, United States of America and the Receiver-Claimants, hereby respectfully request that the deadlines in this case be extended to the following schedule: 1. 2. 3. 4. 5. 6. Complete discovery by: Disclosure of experts by: Disclosure of rebuttal experts by: Dispositive motions by: Pre-Trial Conference: Trial-Ready Date: August 15, 2007 September 17, 2007 October 1, 2007 October 15, 2007 November 5, 2007 December 10, 2007

The United States is also filing motions for extension in all of the Frankel-related forfeiture actions,1 except the two cases that have been stayed,2 and this case.

United States v. 889 Lake Avenue, 3:99CV979, United States v. $11,014,165.20, et al. 3:99CV2589, United States v. 1995 Turbo Commander Aircraft, et al., 3:99CV2590, United States v. 50 Cases of Wine, 3:00CV2008, United States v. `99 Chevy Tahoe, et al., 3:00CV2007, United (continued...)

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Case 3:00-cv-01910-EBB

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Filed 04/23/2007

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As with the other Frankel-related cases, the United States and Receiver-Claimants have been working together in an effort to resolve this case. Due to the complexity of the cases and multiple Receiver-Claimants involved, more time is needed to continue to explore the possibility of settlement. On April 20, 2007, pursuant to Fed. R. Civ. P. 55(a), the Court granted the ReceiverClaimants' motion for default as to their Joint Cross-Claim against Arthur Grant. A motion for default judgment as to the Receiver-Claimants' Joint Cross-Claim is due to be filed with the Court within thirty (30) days. In light of the litigation between the Receiver-Claimants and Claimant Arthur Grant, this case will need more time than the other Frankel-related forfeiture actions and the proposed dates outlined above are advanced by approximately two months compared to the extensions sought in the other cases. The parties therefore respectfully request an extension of the deadlines as outlined above. This is the sixth motion for extension filed with respect to these deadlines. Counsel for the Receiver-Claimants concur with this request and the proposed dates outlined above and support

(...continued) States v. $596,013.77, et al., 3:00CV2010, United States v. $662,310.79, et al., 3:00CV2009, United States v. $135,384.88, 3:04CV1083, United States v. 895 Lake Avenue, 3:99CV1772 (EBB). United States v. $29,035,500.00 & $3,241,500.00, Civil No. 3:01CV1515 (EBB), and United States v. 277 Diamonds, et al., Civil No. 3:02CV889 (EBB). 2
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Case 3:00-cv-01910-EBB

Document 69

Filed 04/23/2007

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the granting of this motion. Counsel for the Claimant, Arthur Grant, has indicated that he also concurs with the request for extension and proposed dates.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY 157 CHURCH STREET NEW HAVEN, CT 06510 TEL. (203) 821-3700 FAX (203) 773-5373 FEDERAL BAR # ct23398

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Case 3:00-cv-01910-EBB

Document 69

Filed 04/23/2007

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Sixth Motion to Extend Scheduling Deadlines has been mailed, postage prepaid, this 23rd day of April, 2007, to: J. Stanley Sanders, Esq. 2015 Wellington Road Los Angeles, CA 90016-1824 Douglas J. Schmidt, Esq. Tessa K. Jacob, Esq. Terrance Summers, Esq. Blackwell Sanders Peper Martin, LLP 4801 Main Street, Suite 1000 Kansas City, MO 64112 Douglas S. Skalka, Esq. Neubert, Pepe & Monteith 195 Church Street New Haven, CT 06510 Graham Matherne, Esq. Wyatt Tarrant & Combs 2525 West End Avenue, Suite 1500 Nashville, Tennessee 37203 Charles G. Copeland, Esq. Copeland, Cook, Taylor & Bush, P.A. 1062 Highland Colony Parkway, Ste. 200 P.O. Box 6020 Ridgeland, Mississippi 39157 Andrew B. Campbell Wyatt, Tarrant & Combs 2525 W. End Avenue Suite 1500 Nashville, TN 37203 Susan Loving, Esq. Lest, Loving and Davies 1701 South Kellly Edmund, Oklahoma 73013

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY

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