United States District Court, D. Nevada
UNITED
STATES ATTORNEY JAMES E. KELLER, Attorney for Plaintiff.
COLE
RADOVICH / Trial Attorney Narcotic and Dangerous Drug Section
Criminal Division / U.S. Department of Justice.
JOHN
LLOYD SNOOK, III Snoot & Haughey, P.C. Attorney for
Defendant, Charles Burton Ritchie.
SHAWN
R. PEREZ, ESQ. Law Office of Shawn R. Perez Attorney for
Defendant, Ryan Matthew Eaton.
CHESNOFF & SCHONFELD DAVID Z. CHESNOFF, ESQ. RICHARD A.
SCHONFELD, ESQ. Attorney for Defendan t, Benjamin Galecki.
STIPULATION TO CONTINUE PRETRIAL MOTION DEADLINES
CALENDAR CALL AND TRIAL DATE [PROPOSED ORDER]
IT
IS HEREBY STIPULATED and AGREED by and between James
E. Keller, Assistant United States Attorney, Charles Anthony
Miracle, U.S. Department of Justice, Cole Arnold Radovich,
U.S. Department of Justice, and David Z Chesnoff, Esq., and
Richard A. Schonfeld, attorney for Defendant, Benjamin
Galecki and John Lloyd Snook, III, Esq., attorney for
Defendant, Charles Burton Ritchie, and Shawn R. Perez, Esq.,
attorney for Defendant, Ryan Matthew Eaton, that Defendants
shall have to and including January 16, 2018, within which to
file the Defendant's pretrial motions.
IT
IS FURTHER STIPULATED AND AGREED, by and between the
parties herein, that the government shall have to and
including, February 9, 2018, within which to file any and all
responsive pleadings.
IT
IS FURTHER STIPULATED AND AGREED, by and between the
parties herein that the Defendant shall have to and
including, February 19, 2018, within which to file any and
all replies to said motions.
That
the calendar call scheduled for May 15, 2018 at 8:45 a.m. in
this matter will commence on the scheduled date and time and
is not impacted by this Stipulation. That the trial in this
matter currently scheduled for May 21, 2018, at the hour of
9:00 a.m., will commence on the scheduled date and time and
is not impacted by this Stipulation.
While
the parties agree to the above stated extensions of deadlines
the parties disagree on whether grounds asserted on prior
motions briefed before the court can or cannot be filed at
this juncture, which this stipulation does not address.
Accordingly,
This Stipulation is entered into for the following reasons:
1. That
Counsel Schonfeld has just recently substituted in for
Defendant Galecki and has not received discovery in this
matter; notwithstanding multiple requests having been made to
prior counsel William H. Gamage;
2. That
Counsel Schonfeld needs the additional time to prepare
pretrial Motions as a result of his recent appearance in this
case;
3. That
Counsel Schonfeld has been in communication counsel for the
co-defendants and counsel for the government and there is no
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