Opinion
2:15-cr-00285-APG-EJY-2
12-06-2022
UNITED STATES OF AMERICA Plaintiff, v. BENJAMIN GALECKI, Defendant.
RENE L. VALLADARES Federal Public Defender JASON FRIERSON United States Attorney AMY B. CLEARY Assistant Federal Public Defender DANIEL D. HOLLINGSWORTH Assistant United States Attorney
RENE L. VALLADARES Federal Public Defender
JASON FRIERSON United States Attorney
AMY B. CLEARY Assistant Federal Public Defender
DANIEL D. HOLLINGSWORTH Assistant United States Attorney
JOINT STIPULATION FOR EXTENSION OF TIME TO FILE DEFENDANT'S RESPONSE TO THE GOVERNMENT'S MOTION TO SUBSTITUTE AND FORFEIT PROPERTY (ECF NO. 582)
(THIRTEENTH REQUEST)
The parties, through their respective counsel, request the current December 7, 2022, deadline for Mr. Galecki's Response to the Government's Motion to Substitute and Forfeit Property be extended by 90 days, with the deadline reset for March 7, 2023.
Counsel for the government, Mr. Galecki, and co-defendant Charles Burton Ritchie are still negotiating the terms of a stipulation that addresses for final resolution the substitution and forfeiture issues before the Court and, if successful, would negate the need for Mr. Galecki to file a Response. However and despite continued significant progress, two events necessitate additional time to resolve this process.
First, Mr. Galecki's ongoing recovery from emergent quintuple bypass surgery in September has hindered the ability of his counsel to communicate with him until relatively recently.
Second, the government provided the most recent proposed edits to the joint stipulation draft to defense counsel in October. Counsel for Mr. Galecki and Mr. Ritchie are now revising that draft for presentation to Mr. Ritchie's spouse, Stephanie Ritchie. Additional time is thus necessary for this step in the revision process, as well as for consideration of the revisions by Stephanie Ritchie and her counsel.
The additional time requested will thus allow continued negotiation of the draft stipulation. If, however, negotiations are unsuccessful, Mr. Galecki will file his Response to the Government's Motion to Substitute and Forfeit Property (ECF No. 582), present his own proposed forfeiture order for the Court's consideration, or submit any other necessary motion for the Court's consideration.
Counsel do not make this request for purposes of delay but act with diligence and for the purpose of resolving the final forfeiture order in an efficient manner without extended litigation and without unnecessarily taxing judicial resources.
Counsel thus respectfully jointly request a 90-day extension of Mr. Galecki's Response.
This is the thirteenth request for an extension of time.
ORDER RESETTING DEADLINE FOR DEFENDANT'S RESPONSE TO THE GOVERNMENT'S MOTION TO SUBSTITUTE AND FORFEIT PROPERTY (ECF NO. 582)
IT IS HEREBY ORDERED that the current December 7, 2022, deadline for Defendant's Response to the Government's Motion to Substitute and Forfeit Property (ECF No. 582) is vacated, extended by 90 days, and reset for March 7, 2023, by which Mr. Galecki shall either submit his Response, any other filing he deems appropriate, or a signed stipulation by all the relevant parties resolving the forfeiture issues.