United States District Court, D. Nevada
BOGDEN United States of America ALEXANDRA MICHAEL Assistant
U.S. Attorney Counsel for the Plaintiff.
ARMSTRONG TEASDALE LLP KEVIN R. STOLWORTHY CONOR FLYNN
Counsel for Defendant Robert Kincade.
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE
OBJECTIONS TO REPORT AND RECOMMENDATION
HEREBY STIPULATED AND AGREED, by and between Alexandra
Michael, Assistant United States Attorney, counsel for the
United States of America, and Robert Kincade, and his counsel
Kevin R. Stolworthy, that the deadline to object to the
Magistrate Judge's Report and Recommendation at ECF No.
238 be extended to February 7, 2017 for the following
January 5, 2017, Kevin Stolworthy, Esq. was appointed as
counsel of record for Mr. Kincade with respect to Count One
only of the Third Superseding Indictment in this case. ECF
Count One pertains to an alleged September 12, 2011 robbery
of a City National Bank in Las Vegas, Nevada.
Kincade is currently being represented by Kathleen Bliss,
Esq, on the remaining Counts contained in the Superseding
Count One has been severed from the remaining Counts
contained in the Third Superseding Indictment, and trial is
currently scheduled for Count One only on March 28, 2017 at
9:00 a.m. ECF No. 214.
Trial is scheduled on the remaining Counts on February 28,
2017 at 9:00 a.m. ECF No. 165.
Prior to Mr. Stolworthy's appointment in the case, on
December 29, 2016, the Magistrate Judge issued a Report and
Recommendation denying Mr. Kincade's Motion to Dismiss
Second Superseding Indictment [ECF No. 169]. See ECF
Objections to this Report and Recommendation are due within
14 days of December 29, 2016.
Parties agree that because Mr. Stolworthy was just appointed
in this case, has not yet obtained the file from former
counsel Todd Leventhal, Esq., and has not obtained a
transcript of the hearing held on Mr. Kincade's Motion on
December 14, 2016, see ECF No. 224, that an
extension of time to February 7, 2017 of the deadline to
object to the Report and Recommendation at ECF No. 238 is
Defendant is incarcerated and does not object to the
additional time requested herein is not sought for purposes
OF FACT, ...