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United States of America v. M. Mark

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA


May 6, 2013

UNITED STATES OF AMERICA, PLAINTIFF,
v.
M. MARK ,
DEFENDANT.

UNITED STATES OF AMERICA'S UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO DEFENDANT DAVID MARK'S OBJECTION TO POST VERDICT ORDER OF FORFEITURE AND REQUEST FOR HEARING (ECF NO. 153) (First Request)

The United States of America ("United States"), by and through Daniel G. Bogden, United States Attorney for the District of Nevada, and Daniel D. Hollingsworth, Assistant United States Attorney ("AUSA"), respectfully moves this Honorable Court for an Order extending the time for the United States to file a Response to Defendant David Mark's Objection To Post Verdict Order Of Forfeiture and Request for Hearing (ECF No. 153) pursuant to Fed. R. Crim. P. 45(b)(1) and LCR 45-1. The Response is currently due May 3, 2013. Order, ECF No. 154. The United States requests an extension of time to and including May 24, 2013. This is the first request for an extension of time. The grounds for extending the time are as follows.

Many pleadings have been filed in numerous criminal cases requiring undersigned counsel to respond, and seven civil cases require immediate attention because of upcoming deadlines recently imposed. Undersigned counsel cannot meet all of the deadlines in these cases and needs an extension of On April 29, 2013, undersigned counsel spoke with opposing counsel, Michael S. Fawer, who stated he did not oppose this extension of time and authorized the three week extension.

This motion is not submitted solely for the purpose of delay or for any other improper purpose.

This Court should grant an extension of time to and including May 24, 2013, pursuant to Fed. R. Crim. P. 45(b)(1) and LCR 45-1, for the United States to file a Response to Defendant David Mark's Objection To Post Verdict Order Of Forfeiture and Request for Hearing (ECF No. 153).

DATED this 1st day of May, 2013. DANIEL G. BOGDEN United States Attorney /s/Daniel D. Hollingsworth DANIEL D. HOLLINGSWORTH Assistant United States Attorney

IT IS SO ORDERED:

UNITED STATES DISTRICT JUDGE

20130506

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