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

Case 3:00-cv-01910-EBB

Document 42

Filed 06/30/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : 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] :

Civil No. 3:00CV1910 (EBB)

June 30, 2005

PLAINTIFF UNITED STATES OF AMERICA'S MOTION FOR EXTENSION OF TIME TO COMPLETE DISCOVERY Pursuant to Local Rule 7(b), the Plaintiff, United States of America, respectfully requests an extension of time from July 1, 2005 until September 16, 2005, within which to complete discovery in this case. The parties in the case are the Plaintiff, United States of America, Arthur F. Grant, and the following victim insurance companies: (1) Mississippi Commissioner of Insurance George Dale, Liquidator of First National Life Insurance Company of America, Franklin Protective Life Insurance Company, and Family Guaranty Life Insurance Company; (2) Commissioner Anne B. Pope, Receiver and Liquidator of Franklin American Life Insurance Company; (3) Director Keith Wenzel, Receiver of International Financial Services Life Insurance Company; (4) Carroll Fisher,

Case 3:00-cv-01910-EBB

Document 42

Filed 06/30/2005

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Insurance Commissioner and Receiver for Farmers and Ranchers Life Insurance Company; (5) Mike Pickens, Receiver of Old Southwest Life Insurance Company. Thus far in the litigation, the parties have engaged in some informal discovery. As part of the ongoing effort to resolve the Frankel-related forfeiture actions, the United States and Receiver-Claimants would like more time to conduct further discovery to aid in the resolution of the outstanding claim of Arthur F. Grant in this case. The additional time would therefore be appreciated. This is the first motion to extend this time limitation. Counsel for Claimant Arthur F. Grant and Counsel for the Receiver-Claimants have indicated that they have no objection to this motion for extension of time and also join in moving for more time to complete discovery. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct23398

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Case 3:00-cv-01910-EBB

Document 42

Filed 06/30/2005

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Plaintiff United States of America's Motion to Extend Time to Complete Discovery has been mailed, postage prepaid, on this 30th day of June, 2005, to: J. Stanley Sanders, Esq. 2015 Wellington Road Los Angeles, CA 90016-1824 Douglas J. Schmidt, Esq. Blackwell Sanders Peper Martin, LLP 2300 Main Street, Suite 1000 Kansas City, Missouri 64108 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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