Government's Unopposed Motion To Extend the Time to Respond to Motion for Release of Funds for Purposes of Paying Civil Settlement (ECF No. 249)

(Third Request)

ANDREW P. GORDON, District Judge.

The United States of America respectfully moves this Court for an Order extending the time for the government to respond to defendants' Motion for Release of Funds for Purposes of Paying Civil Settlement (ECF No. 249). The original deadline for responding to the Motion was January 3, 2019. In the first request, the government requested an extension of time to and including January 17, 2019, that this Court granted (ECF Nos. 250, 251). The government requested a second extension of time to and including February 15, 2019, that this Court granted (ECF Nos. 225 and 256). The government requests a third extension of time to and including February 25, 2019.

The grounds for extending the time are as follows.

On February 8, 2019, the undersigned counsel contacted Richard Schonfeld, counsel for defendants by phone who agreed to this extension of time because of the reasons cited below.

The undersigned has a large and active case load. Due to the recent government shutdown, undersigned was furloughed and work accumulated that must be addressed immediately in other criminal cases because of upcoming sentencing hearings. Undersigned has worked extremely hard and efficiently to meet all the deadlines, but he has not had time to address the Response.

The Asset Forfeiture Unit (AFU) in the United States Attorney's Office for the District of Nevada (USAO) is understaffed. AFU lacks two paralegal specialists and one full time forfeiture Assistant United States Attorney (AUSA) in Las Vegas and one AUSA in Reno, Nevada. The undersigned is currently the only forfeiture AUSA in the USAO. The forfeiture criminal cases in Reno, Nevada, have been added to undersigned's workload. Between the lack of staff, the lack of forfeiture AUSAs, the shutdown, and the criminal forfeiture workload, the forfeiture work in the USAO has backed up significantly. The undersigned is doing the best he can under the circumstances.

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, February 25, 2019, for the United States to respond to defendants' motion (ECF No. 249).

IT IS SO ORDERED.