United States District Court, D. Nevada
L. VALLADARES Federal Public Defender
LAZO Assistant Federal Public Defender Counsel for Nicholas
W. MYHRE Acting United States Attorney
J. COUMOU Assistant United States Attorney
STIPULATION TO CONTINUE PRELIMINARY HEARING (FIRST
HONORABLE CAM FERENBACH UNITED STATES MAGISTRATE JUDGE
HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre,
Acting United States Attorney, and Frank Johan Coumou,
Assistant United States Attorney, counsel for the United
States of America, and Rene L. Valladares, Federal Public
Defender, and Raquel Lazo, Assistant Federal Public Defender,
counsel for Nicholas Omarjuen Lewis, that the Preliminary
Hearing currently scheduled for June 5, 2017 at 4:00 p.m. be
vacated and set to a date and time convenient to this Court,
in fourteen (14) days.
Stipulation is entered into for the following reasons:
Counsel for the Defendant and the Government are awaiting
Counsel for the Defendant and the Government have discussed
Defendant is incarcerated and does not object to the
parties agree to the continuance.
additional time requested herein is not sought for purposes
of delay, buy merely to allow counsel for both parties
sufficient time within which to receive and review discovery
and be able to effectively analyze the case.
Additionally, denial of this request of continuance could
result in a miscarriage of justice. The additional time
requested by this Stipulation is excusable in computing the
time within which the preliminary hearing herein must
commence pursuant to the Speedy ...