UNITED STATES OF AMERICA'S UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLIES TO OBJECTION TO SUBSTITUTION OF UNITED STATES OF AMERICA AS DEFENDANT (ECF NO. 10), PLAINTIFF'S OPPOSITION TO MOTION TO STAY DISCOVERY (ECF NO. 11), and PLAINTIFF'S OPPOSITION TO MOTION TO DISMISS

(ECF NO. 12)

GLORIA M. NAVARRO, District Judge.

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, respectfully moves this Honorable Court for an Order extending the time, pursuant to Fed. R. Civ. P. 6(b), LR 6-1, and LR 6-2, for the United States to file responsive pleadings. The deadline to file the Replies is currently June 18, 2013. The United States requests to and including July 26, 2013, to file the Replies. This is the third request for extensions of time. The grounds for extending the time are as follows.

An individual of the Civil Air Patrol ("CAP") had medical issues, was in the hospital, and will return to his CAP office on June 17, 2013. The attorney for the Air Force has had personal matters that relate to serious medical issues for a family member and will be out for the next few weeks, assisting in the medical and rehabilitation of that family member. The undersigned attorney will be unavailable for the next couple of weeks on personal matters and has had to respond to numerous criminal cases (that went to trial) regarding criminal forfeiture and criminal forfeiture money judgment issues, address numerous civil forfeiture cases, additional civil defensive cases, and had to respond to a Writ of Mandamus on short notice.

Additionally, although undersigned counsel has addressed numerous civil forfeiture in rem cases and criminal forfeiture cases either by filing the necessary pleadings or by requesting extensions of time, he still cannot meet all of the deadlines in these cases and needs extensions of time in this case to file the Replies. The United States needs additional time for the necessary people to provide the necessary information and documents to prepare the Replies. The United States requests this Court allow the United States to and including July 26, 2013, to file the Replies.

On June 13, 2013, undersigned counsel for the United States called Robert S. Cardenas, counsel for Plaintiff, who did not object to and agreed to the extensions of time to file the Replies.

This motion is not submitted solely for the purpose of delay or for any other improper purpose. Based on Fed. R. Civ. P. 6(b), LR 6-1, and LR 6-2 and the forgoing reasons, this Court should grant an extension of time to and including June 18, 2013, for the United States to file the Replies.

ORDER

IT IS HEREBY ORDERED that the United States' for extension of time to file its Reply to Plaintiff's Objection to Substitution of United States of America as Defendant (ECF No. 10) and Plaintiff's Opposition to Motion to Dismiss (ECF No. 12) is hereby GRANTED. The United States of America shall have through and including July 26, 2013, to file its replies to the aforementioned Objection (ECF No. 10) and Opposition (ECF No. 12).