United States District Court, D. Nevada
A. Ericsson, Esq. Oronoz, Ericsson & Gaffney, LLC
Attorney for Bret Alan Humphries
Coumou, Esq. Assistant United States Attorney Attorney for
the United States of America
STIPULATION TO EXTEND TIME TO FILE REPLY TO THE
GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL
DISCOVERY (Dkt. 127)
HEREBY STIPULATED AND AGREED by BRET ALAN HUMPHRIES, by and
through his attorney, THOMAS A. ERICSSON, ESQ., and the
United States of America, by and through FRANK COUMOU, ESQ.,
Assistant United States Attorney, that the date for the
defendant to respond to the Government's Response to
Defendant's Motion to Compel Discovery (Dkt. 127) be
extended up to and including June 23, 2017. The request for a
continuance is based upon the following:
1. On May 24, 2017, the Defendant filed a Motion to Compel
Discovery (See, Dkt. 126).
2. On June 7, 2017, the Government filed its Response to the
Defendant's Motion to Compel Discovery (See,
3. Counsel for the Defendant requires additional time to
finalize his reply to the Government's Response because
he requires the assistance of his expert to prepare the
reply, and the expert is currently in trial.
4. Defendant Humphries is currently in custody and has no
objection to the continuance.
5. Defense counsel for BRET ALAN HUMPHRIES has spoken to AUSA
Frank Coumou, and he has no objection to the continuance of
the briefing schedule.
6. The additional time requested herein is not sought for
purposes of delay.
7. Denial of this request for a continuance would deny
counsel for the defendant sufficient time, to effectively and
thoroughly prepare and submit pretrial motions and notices of
defense, taking into account the exercise of due diligence.
8. Additionally, denial of this request for continuance could
result in a miscarriage of justice.
9. 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, Section 3161(h)(7)(A), considering
the factors under Title 18, United States Code §§
3161(h)(7)(B)(i) and 3161(h)(7)(B)(iv).
the first request to extend the time to file this reply.