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United States v. Washington

United States District Court, D. Nevada

June 7, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
JOSHUA SADAT WASHINGTON, AND FEDEL EZEKIEL SAKERS Defendants.

          RENE L. VALLADARES Federal Public Defender,

          REBECCA A. LEVY Assistant Federal Public Defender, Attorney for Joshua Sadat Washington

          STEVEN W. MYHRE, Acting United States Attorney

          ROBERT KNIEF. Assistant United States Attorney

          CHRISTOPHER ORAM, Esq. Counsel for Fedel Ezekiel Sakers

          STIPULATION TO CONTINUE MOTION DATES ONLY

         IT IS HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre, Acting United States Attorney, and Robert Knief., Assistant United States Attorney, counsel for the United Stated of America, and Rene L. Valladares, Federal Public Defender, and Rebecca A. Levy, Assistant Federal Public Defender, counsel for Joshua Sadat Washington, and Christopher Oram, counsel for Fedel Ezekiel Sakers that the parties herein shall have to and including June 29, 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 July 6 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 July 13, 2017, to file any and all replies to dispositive motions.

         The Stipulation is entered into for the following reasons:

         1. Both defendants are in custody but do not oppose the continuance.

         2. Since the filing of the previous stipulation counsels for the defendants have been diligent in case preparation. However, additional time is needed to allow the respective counsels for the defendants sufficient time to review recently received discovery.

         3. Denial of this request for continuance would deny counsels for the defendants sufficient time to effectively and thoroughly prepare, taking into account the exercise of due diligence.

         4. 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, § 3161(h)(7)(A), ...


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