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

Case 3:00-cv-01910-EBB

Document 62

Filed 12/05/2006

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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)

December 5, 2006

FIFTH MOTION TO EXTEND SCHEDULING DEADLINES The Plaintiff, United States of America, hereby respectfully requests 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: April 15, 2007 May 15, 2007 May 29, 2007 June 15, 2007 July 2, 2007 August 8, 2007

Case 3:00-cv-01910-EBB

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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 stayed2, to align all of the cases with this proposed schedule. The parties had requested a fourth discovery extension until October 6 , 2006, due to the Receiver-Claimants' pending Joint Motion for Default Judgment on Cross-Claim Against Arthur Grant. The motion remains pending before the Court. Once the Court issues a ruling, the parties will assess the need for additional discovery, experts, or other dispositive motions. The parties therefore respectfully request an extension of the deadlines as outlined above. This is the fifth motion for extension filed with respect to these deadlines. Counsel for the Receiver-Claimants3 concur with this request and the proposed dates outlined above and support

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 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. $140,000, 3:00CV1910. 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). Kim Holland, Commissioner of Insurance for the State of Oklahoma, in her capacity as Receiver of Farmers and Ranchers Life Insurance Company; W. Dale Finke, Director of the Missouri Department of Insurance, in his capacity as Receiver of International Financial Services Life Insurance Company; Paula A. Flowers, Commissioner of Commerce and Insurance for the State of Tennessee, in her capacity as Receiver of Franklin American Life Insurance Company; Julie Benafield Bowman, Commissioner of Insurance for the State of Arkansas, in her capacity as Receiver of Old Southwest Life Insurance Company; and George Dale, Commissioner of Insurance for the State of Mississippi, in his capacity as Liquidator of Family Guaranty Life Insurance Company, Franklin Protective Life Insurance Company, and First National Life Insurance Company of America. 2
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Case 3:00-cv-01910-EBB

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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 62

Filed 12/05/2006

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Fifth Motion to Extend Scheduling Deadlines has been mailed, postage prepaid, this 5th day of December, 2006, 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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