Free Motion to Extend Time - District Court of Arizona - Arizona

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DIANE J. HUMETEWA United States Attorney District of Arizona JOHN BOYLE Assistant U.S. Attorney Two Renaissance Square 40 North Central Ave, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 015640 Telephone (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, CR-04-0014-001- PHX-DGC Plaintiff, v. RUBEN LOPEZ-FELIX, Defendant. UNITED STATES' MOTION TO EXTEND RESPONSE ON DEFENDANT'S REVISED PETITION FOR EXONERATION AND RETURN OF BAIL

The United States of America, by and through its undersigned attorney, respectfully requests the Court extend the Government's response on the Defendant's Revised Petition for Exoneration and Return of Bail. The Government previously filed, on March 3, 2008, an objection to the Defendant's Motion. The United States requests the ruling be held in abeyance to permit supplemental response by April 1, 2008. The government intends to pursue forfeiture of the bond posted by Defendant in satisfaction of this Court's Final Order of Forfeiture dated September 20, 2006. However, the parties are attempting to resolve this matter by stipulation. Specifically, the Defendant's attorney, Jilbert Tahmazian is attempting to obtain the records demonstrating ownership of the $100,000 cash posted for the bond. If the records prove 3rd-party ownership of the funds, the government's forfeiture attempt could become futile. Therefore, the government requests an extension to April 1, 2008, to supplement it's position regarding exoneration of bond. Defendant's attorney has been contacted and has no objection to this request. // //

Case 2:04-cr-00014-DGC

Document 116

Filed 03/18/2008

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Respectfully submitted 18th day of March, 2008. DIANE J. HUMETEWA United States Attorney District of Arizona s/ John Boyle JOHN BOYLE Assistant U.S. Attorney

CERTIFICATE OF SERVICE I hereby certify that on March 18, 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: Brian Russo 111 W. Monroe St., Ste. 1212 Phoenix, AZ 85003 [email protected] Jilbert Tahmazian 1518 W. Glenoaks Blvd. Glendale, CA 91201 [email protected]

B. Boyers

B. Boyers

Case 2:04-cr-00014-DGC

Document 116

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Filed 03/18/2008

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