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United States v. Barbosa

United States District Court, D. Nevada

April 11, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
PEDRO IGOR ALVES BARBOSA, et. al. Defendants.

          John Patrick Burns Assistant United States Attorney Counsel for the Plaintiff.

          David R. Fischer Amdre Araiyo Rodrigues.

          Patricia M. Erickson Counsel for Defendants Barbosa and Dos Reis.

          Bret O. Whipple Francisco Rui de Alencar Mendes Filho.

          JOINT STIPULATION TO CONTINUE PRETRIAL MOTIONS (FIRST REQUEST)

         IT IS HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre, Acting United States Attorney, and John Patrick Burns, Assistant United States Attorney, counsel for the United States of America, and Patricia M. Erickson, counsel for defendants Pedro Igor Alves Barbosa and Vitor Domingues Valentini Do Reis, David R. Fischer, counsel for defendant Andre Araiyo Rodrigues, and Bret O. Whipple, counsel for defendant Francisco Rui de Alencar Mendes Filho that defendants will have to and including May 26, 2017 within which to file the defendants' pretrial motions.[1]

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that the government shall have to and including June 9, 2017 within which to file any and all responsive pleadings.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that the defendants shall have to and including June 16, 2017 within which to file any and all replies to the pretrial motions.

         This Stipulation is entered into for the following reasons:

         1. That discovery in this case is voluminous. Counsel for the defendants were required to submit a three terabit hard drive for the government to download the discovery.

         2. That the government is in the process of downloading the discovery to the individual hard drives.

         3. That defendants Dos Reis, Filho and Rodrigues were arraigned on March 10, 2017. Defendant Barbosa was arraigned on March 30, 2017.

         4. That once discovery is received from the government, counsel for the defendants will need additional time to review the discovery.

         5. That the defendants are incarcerated and do not object to the continuance of the dates for the filing of ...


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