STIPULATION TO CONTINUE DISCOVERY, MOTION, AND ANCILLARY HEARING DATES; ORDER THEREON

LAWRENCE K. KARLTON, District Judge.

IT IS HEREBY STIPULATED between the United States and Petitioners Bank of Montreal, Stefanie A. Gallegly and Caroline G. Salyer, individually and as beneficiaries of the Caroline G. Salyer and Stefanie A. Gallegly Irrevocable Trusts dated March 29, 1999, and Robert Pruett, trustee of the Caroline G. Salyer and Stefanie A. Gallegly Irrevocable Trusts dated March 29, 1999, by and through their undersigned attorneys, THAT:

1. Subject to the Court's approval, the United States and Petitioners propose to continue dates currently set for Discovery Cutoff, Dispositive Motions Cutoff, and the Ancillary Hearing Date,1 to September 3, October 3, and November 12, 2013, respectively, in order to allow the parties to coordinate international discovery requests with the governments of Liechtenstein and Andorra. Given the nature of the case and types of documents requested (bank records), the United States understands that it will take several months to obtain the bank account information from Andorra and Liechtenstein.

2. The proposed continuances are further necessary in light of the parties' need to sync the discovery schedules among other petitioners in the ancillary proceeding, which all involve the international requests for information to Liechtenstein and Andorra. As explained in previous court filings, the forfeited funds at issue in the ancillary proceeding are currently overseas and the petitioners' claims are premised on tracing funds through various bank accounts in the United States, Liechtenstein and Andorra. The bank account information is necessary to resolve the factual disputes underlying the petitions filed in the ancillary proceeding.

3. The proposed litigation schedule:

ORDER

IT IS HEREBY ORDERED THAT:

1. Discovery cutoff is set for 09/03/2013;

2. Last day to file dispositive motions set for 10/03/2013; and

3. Ancillary Hearing set for 11/13/2013 at 09:15 AM in Courtroom 4 before Judge Lawrence K. Karlton