UNITED STATES' UNOPPOSED MOTION TO CONTINUE THE DATE TO FILE ITS COMPLAINT FOR FORFEITURE IN REM IN THE ABOVE-CAPTIONED MATTER AND ORDER

MIRANDA M. DU, District Judge.

The United States of America ("United States"), by and through Daniel G. Bogden, United States Attorney, and Michael A. Humphreys, Assistant United States Attorney, respectfully applies for an extension of time until and including May 21, 2013, pursuant to 18 U.S.C. § 983(a)(3)(A), for the United States to file a Civil Complaint for Forfeiture In Rem against the $49,205.27 in United States Currency. The Government's Complaint is currently due January 21, 2013.

Gregg Gariti and numerous associates of his have been the focus of a historical state/federal criminal investigation into their activities of alleged unlawful gaming activities in Nevada and elsewhere. Generally speaking, the Government has developed information that Gariti and others were operating an illegal book-making operation from approximately December 2008 through approximately April 2009, all in violation of 18 U.S.C. § 1084 and other federal anti-gambling statutes. A principal situs of that illegal operation was Las Vegas, Nevada.

Pursuant to plea negotiations between Mr. Gariti and the Government, on September 24, 2009, Mr. Gariti entered a change of plea before this Court.

In the meantime, the Government has a deadline, under the strictures of 18 U.S.C. § 983 (a)(3)(A), to file its forfeiture complaint, regarding the above-captioned currency, no later than January 21, 2013.

The criminal case will not be disposed of by the time the Government is required to file its complaint. However, counsel for the United States believes that there will be a final disposition of this matter before the expiration of the time period for the continuance requested herein; making further requests for continuances unnecessary.

Finally, on January 14, 2013, defendant's counsel, Margaret Stanish, agreed to the extension of time and authorized counsel for the United States to file this Unopposed Motion with this Court. Because the parties have agreed to the extension of time to file a Civil Complaint For Forfeiture In Rem and to facilitate a final universal plea/sentencing disposition, this Court should extend the time.

This motion is not submitted solely for the purpose of delay or for any other improper purpose.

WHEREFORE, the United States moves this Court to grant its motion to extend the time for the United States to file its civil complaint in the above-captioned matter for an additional 120 days, or until May 21, 2013.