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United States v. Gibson

United States District Court, D. Nevada

January 10, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
ROBERT LEE GIBSON, Defendant.

          ALEXANDRA MICHAEL Assistant United States Attorney Counsel for the United States.

          RAQUEL LAZO Counsel for Defendant ROBERT LEE GIBSON.

          STIPULATION TO CONTINUE DEADLINE FOR GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION TO SUPPRESS (DOC #19)

         IT IS HEREBY STIPULATED AND AGREED, by and between Daniel G. Bogden, United States Attorney, and Alexandra Michael., Assistant United States Attorney, counsel for the United States of America, and Raquel Lazo, Esq., counsel for Defendant ROBERT LEE GIBSON, that the deadline for Government's Response to Defendant's Motion to Suppress, currently set for January 9, 2017, Doc. #19, be vacated and continued for seven (7) days, until January 16, 2017, or to a date to be set at the Court's convenience.

         This stipulation is entered for the following reasons:

         1. The government needs additional time to review Defendant's Motion to Suppress and file a response.

         2. The parties agree to the continuance.

         3. For the reasons stated above, the ends of justice would best be served by a continuance of the deadline.

         4. Additionally, denial of this request for continuance could result in a miscarriage of justice.

         5. The additional time requested by this Stipulation is excludable in computing the time within which the trial herein must commence pursuant to the Speedy Trial Act, Title 18, United States Code, Section 3161(h)(1)(D) and 3161(h)(7) and Title 18, United States Code, Section 3161(h)(7)(A) and (h)(3)(A), when considering the facts under Title 18, United States Code, Sections 3161(h)(7)(B), 3161(h)(7)(B)(i), and 3161(h)(7)(B)(iv).

         6. This is the first request for a continuance filed herein.

         ORDER CONTINUING GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION TO SUPPRESS (Doc #19)

         FINDING OF FACTS

         This stipulation is entered for the following reasons:

         1. The government needs additional time to review Defendant's Motion ...


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