Opinion
2:08-CR-332-JCM-(GWF)
03-26-2013
UNITED STATES OF AMERICA, Plaintiff, v. DWIGHT RAMON POLLARD, Defendant.
DANIEL G. BOGDEN United States Attorney DANIEL D. HOLLINGSWORTH Assistant United States Attorney
DANIEL G. BOGDEN
United States Attorney
Nevada Bar No. 2137
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney
Nevada State Bar No. 1925
Lloyd D. George United States Courthouse
333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
Telephone: (702) 388-6336
Facsimile: (702) 388-6787
E-mail: Daniel.Hollingsworth@usdoj.gov
Counsel for the United States of America
THE UNITED STATES OF AMERICA'S UNOPPOSED MOTION TO EXTEND TIME TO
RESPOND TO DEFENDANT POLLARD'S OBJECTION TO ENTRY OF A CRIMINAL
FORFEITURE MONEY JUDGMENT (ECF No. 473)
(Second 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 Dwight Ramon Pollard's Objection To Entry Of A Criminal Forfeiture Money Judgment (ECF No. 473) pursuant to Fed. R. Crim. P. 45(b)(1) and LCR 45-1. The Response is currently due March 25, 2013. The United States requests an extension of time to April 8, 2013. This is the second request for an extension of time.
The grounds for extending the time are as follows.
Another forfeiture AUSA has been out of the United States Attorney's Office and will not return until April 3, 2013. The AUSA assigned to respond to Pollard's Objection has attempted to complete the Response to Pollard's Objection and has been unable to do both his job and cover the responsibilities of the other forfeiture AUSA. On March 25, 2013, the AUSA spoke with opposing counsel, Jason F. Carr, who stated he did not oppose this extension of time and authorized as much time as was needed.
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 April 8, 2013, pursuant to Fed. R. Crim. P. 45(b)(1) and LCR 45-1, for the United States to file a Response to Defendant Pollard's Objection To Entry Of A Criminal Forfeiture Money Judgment (ECF No. 473).
DANIEL G. BOGDEN
United States Attorney
______________________
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney
IT IS SO ORDERED:
______________________
UNITED STATES DISTRICT JUDGE
PROOF OF SERVICE
I, Daniel D. Hollingsworth, certify that the following individuals were served with copies of THE UNITED STATES OF AMERICA'S UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO DEFENDANT POLLARD'S OBJECTION TO ENTRY OF A CRIMINAL FORFEITURE MONEY JUDGMENT (ECF No. 473) (Second Request) on March 25, 2013, by the below identified method of service:
CM/ECF
Alina M. Shell
Federal Public Defender
411 E. Bonneville, Suite 250
Las Vegas, Nv 89101
Email: Alina_Shell@fd.org
Attorney for Dwight Ramon Pollard
Jason F. Carr
Federal Public Defender
411 E Bonneville, Suite 250
Las Vegas, NV 89101
Email: ECF_Vegas@FD.ORG, jason_carr@fd.org,
Attorney for Dwight Ramon Pollard
______________________
DANIEL D. HOLLINGSWORTH
Assistant United States Attorney