United States v. Ritchie

          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 ...