United States District Court, D. Nevada
L. VALLADARES Federal Public Defender MONIQUE KIRTLEY
Assistant Federal Public Defender.
W. MYHRE Acting United States Attorney KILBY MACFADDEN
Assistant United States Attorney.
AMENDED STIPULATION TO CONTINUE OBJECTIONS TO REPORT
AND RECOMMENDATION [ECF NO. 82] (SECOND REQUEST)
HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre,
Acting United States Attorney, and Kilby Macfadden, Assistant
United States Attorney, counsel for the United Stated of
America, and Rene L. Valladares, Federal Public Defender, and
Monique Kirtley, Assistant Federal Public Defender, counsel
for Virab Torosyan, that the Objections to Magistrate's
Report and Recommendation (ECF No. 82) be extended fourteen
(14) days, from the previous deadline of August 25, 2017, to
September 8, 2017.
Stipulation is entered into for the following reasons:
June 20, 2017, the Magistrate Court held a Motion Hearing
regarding defendant's Motion to Suppress (ECF No. 76).
The Magistrate Court filed its Report and Recommendation on
July 28, 2017. (ECF. No. 82).
August 8, 2017, Defense counsel ordered the transcript from
the Motion to Suppress Hearing. Defense counsel received the
transcript on August 17, 2017. Defense counsel needs time to
finish her objections to the Report and Recommendation (ECF
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, but merely to allow counsel for the defendant
sufficient time review the transcript of the Motion Hearing
and to file written objections to the Report and
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), considering the
factors under Title 18, United States Code §§
the second stipulation to continue filed herein.
on the pending Stipulation of counsel, and good cause