United States District Court, D. Nevada
L. VALLADARES Federal Public Defender
RIDDLE, Assistant Federal Public Defender
G. BOGDEN United States Attorney
C. MACFADDEN, Assistant United States Attorney
STIPULATION TO CONTINUE TRIAL DATES
HEREBY STIPULATED AND AGREED, by and between Daniel G.
Bogden, United States Attorney, and Kilby C. Macfadden.,
Assistant United States Attorney, counsel for the United
States of America, and Rene L. Valladares, Federal Public
Defender, and Paul Riddle, Assistant Federal Public Defender,
counsel for Leon Johnson, that the calendar call currently
scheduled for Wednesday, February 22, 2017 at 1:30 p.m., and
the trial currently scheduled for, Monday, February 27, 2017
at 9:00 a.m., be vacated and set to a date and time
convenient to this Court, but no sooner than sixty (60) days.
Stipulation is entered into for the following reasons:
client is in custody and does not oppose the continuance.
Since the filing of the previous stipulation, counsel for the
defendant has been diligent in trial preparation, as well as
attempts to negotiate a resolution acceptable to the
Defense counsel seeks additional time to continue the process
of consulting with an expert.
Pending the report from the expert, additional time will be
needed to prepare for trial.
additional time requested herein is not sought for purposes
Denial of this request for continuance would deny counsel for
the defendant sufficient time to effectively and thoroughly
prepare, taking into account the exercise of due diligence.
Additionally, denial of this request for continuance could
result in a miscarriage of Justice. 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, §