IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. 11-CV-02106-CBS

UNITED STATES OF AMERICA,

Plaintiff,

v.

DEFENDANT NO 1: ONE PARCEL PROPERTY LOCATED AT

927 COLE STREET, GOLDEN, COLORADO, WITH ALL

APPURTENANCES, IMPROVEMENTS AND ATTACHMENTS

THEREON;

DEFENDANT NO 2: ONE 2008 TOYOTA HIGHLANDER,

VIN # JTEES42A182076495;

Defendants.

SECOND MOTION FOR EXTENSION OF TIME

TO FILE PLEADINGS

The United States of America, by and through Attorney General of the United States Eric

Holder, Barry R. Grissom, United States Attorney for the District of Kansas, through Special

Attorneys, Richard L. Hathaway and Christine E. Kenney, respectfully requests this Court for a

second Order extending the time to file certain pleadings.

1. On February 16, 2012, the Court upon joint motion of the parties entered an Order

extending the deadline to file certain pleadings. (Doc. 38, Order to Continue Scheduling

Conference and Extending Time to File Pleadings.)

2. Since the entry of that Order, the United States has been diligently working to

complete certain tasks before requesting a stay of the instant case pending the outcome of United

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States v. Richard Dalton and Marie Dalton, Case No. 11-430-CMA. However, one last matter

remains outstanding and cannot be completed prior to the current deadline of April 16, 2012.

3. Publication Notice as to Defendant No. 2 commenced on Feb 15, 2012 and

concluded on March 15, 2012. (Doc. 44.) Potential claimants have 30 days after the last

publication day, or until April 15, 2012, to file a claim. Thus, the United States suggest that a

continuance of the deadline to May 14, 2012 will give sufficient time to identify potential

claimants and resolve the proceedings as to Defendant No. 2.

3. Counsel for Marie Dalton has been contacted and does not object to this request

for extension of time. 

Wherefore, the United States respectfully requests that this Court grant this request to

extend the deadline to file the following pleadings currently due April 16, 2012: Motion and

Order for Default Judgment as to Defendant No. 2, and agreed upon Motion and Order to Stay

Proceedings Pending the Outcome of United States v. Richard Dalton and Marie Dalton, Case

No. 11-430-CMA.

DATED: April 9, 2012

Respectfully submitted,

ERIC H. HOLDER, JR.

ATTORNEY GENERAL OF THE UNITED STATES

&

BARRY R. GRISSOM, # 10866

UNITED STATES ATTORNEY

DISTRICT OF KANSAS

barry.grissom@usdoj.gov

by:

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Case No. 1:11-cv-02106-PAB-CBS Document 45 filed 04/09/12 USDC Colorado pg 2 of 3
s/Richard L. Hathaway

rich.hathaway@usdoj.gov

&

s/Christine E. Kenney

christine.kenney@usdoj.gov

Special Attorneys 

444 SE QUINCY, SUITE 290

TOPEKA, KS 66683

Phone: (785) 295-2850

Fax: (785) 295-2853

CERTIFICATE OF SERVICE

I hereby certify that on April 9, 2012, I electronically filed the foregoing with the Clerk of

the Court by using the CM/ECF system which will send a notice of electronic filing to any

counsel of record. 

s/Christine E. Kenney

christine.kenney@usdoj.gov

Special Attorneys 

444 SE QUINCY, SUITE 290

TOPEKA, KS 66683

Phone: (785) 295-2850

Fax: (785) 295-2853

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