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United States v. Hall

United States District Court, D. Nevada

April 14, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
BAILEY AARON HALL, Defendant.

          RENE L. VALLADARES Federal Public Defender

          BRIAN PUGH Assistant Federal Public Defender

          DANIEL G. BOGDEN United States Attorney

          ALEXANDRA MICHAEL Assistant United States Attorney

          STIPULATION TO MOTION DEADLINES

         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 Rene L. Valladares, Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel for Bailey Aaron Hall, that the Motion deadline scheduled for April 14, 2017, be vacated and that the parties herein shall have to and including April 28, 2017, to file any and all pretrial motions and notices of defense.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 12, 2017, to file any and all responsive pleadings.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 19, 2017, to file any and all replies to dispositive motions.

         The Stipulation is entered into for the following reasons:

         1. The parties are engaged in plea negotiations which would obviate the need to file Motions.

         2. The defendant is incarcerated and does not object to the continuance.

         3. The parties agree to the continuance.

         4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to be able to effectively and complete research and file their pretrial motions.

         5. Additionally, denial of this request for continuance could result in a miscarriage of justice. The additional time requested by this Stipulation is excusable 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)(7)(A), ...


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