Free Motion for Hearing or Conference - District Court of Arizona - Arizona

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RICHARD W EBER Chief Asset Forfeiture and Money Laundering Section SCOTT PACCAGNINI Trial Attorney Asset Forfeiture and Money Laundering Section U.S. Department of Justice 1400 New York Avenue, NW W ashington, DC 20005 Telephone: (202) 514-8171 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America,

9 Plaintiff, 10 11 12 Defendant. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 // v. Lear Jet, Model 31A, Serial Number 31A224, U.S. Registration # N224LJ;

CV 04-363-PHX-JWS GOVERNMENT'S MOTION TO TEMPORARILY LIFT THE STAY SOLELY FOR PURPOSES OF A SETTLEMENT CONFERENCE AND REQUEST FOR A SETTLEMENT CONFERENCE

Plaintiff, United States of America, by and through the undersigned, respectfully files this Motion to Temporarily Lift the Stay Solely for Purposes of a Settlement Conference and Request for a Settlement Conference with the Court pursuant to Local Rule of Civil Procedure 83.10 for the following reasons: 1. On February 29, 2008, Plaintiff and Claimants, through their respective counsel, filed a Status Report stating that the parties would meet within thirty (30) days of the filing of the Status Report, with all necessary principals on hand, to further settlement negotiations in the hopes of bringing a prompt global resolution to this matter.

Case 2:04-cv-00363-JWS

Document 201

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2.

While the parties have continued settlement negotiations via telephone, the parties were unable to meet within the thirty (30) days indicated in the February 29, 2008 Status Report.

3.

Plaintiff believes a settlement conference with a Magistrate Judge, with all necessary principals on hand, would greatly assist the parties in bringing a resolution to this matter.

4.

Counsel for Claimants Bombardier Capital Inc. and ScotiaBank Inverlat have advised Plaintiff that they do not object to Plaintiff's Motion.

5.

Counsel for Claimant Abed has advised Plaintiff that she objects to the temporary lifting of the stay but does not object to a settlement conference.

Respectfully submitted this 28 th day of March, 2008.

RICHARD WEBER Chief, Asset Forfeiture and Money Laundering Section S/Scott Paccagnini

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By: Scott Paccagnini

CERTIFICATE OF SERVICE
I hereby certify that on March 28, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:

Lawson Pedigo Miller, Keffer, & Pedigo 8401 North Central Expressway, Suite 630 Dallas, Texas 75225 [email protected] Douglas F. Behm Jennings, Strouss & Salom, P.L.C. The Collier Center, 11th Floor 201 East Washington Street Phoenix, Arizona 85004-2385

[email protected]
Cynthia Orr Goldstein, Goldstein and Hilley 29th Floor Tower Life Building 310 South St. Mary's Street San Antonio, Texas 78205

[email protected]
I hereby certify that on March 28, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing, and served the attached document by U.S. mail, on the following: Geoffrey Young Ruden, McClosky, Smith, Schuster & Russell, P.A. 150 2nd Avenue, Suite 1700 St. Petersburg, FL 33701

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Case 2:04-cv-00363-JWS

Document 201

Filed 03/28/2008

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