United States District Court, D. Nevada
W. MYHRE Acting United States Attorney
PADDA, Esq. Counsel for Defendant LEAVITT
PATRICK BURNS Assistant United States Attorney
CHRISTIANSEN, Esq. Counsel for Defendant LEWIS
COMPLEX CASE SCHEDULE (STIPULATION)
HONORABLE CAM FERENBACH UNITED STATES MAGISTRATE JUDGE.
to Local Rule 16-1, the United States, by and through the
undersigned, and Defendants, by and through undersigned
counsel, submit this Proposed Complex Case Schedule as
parties stipulate that this is a complex case within the
meaning of that term under Title 18, United States Code,
Section 3161(h)(7)(B)(i) and (ii), in that the failure to
grant such a continuance of such proceeding would result in a
possible miscarriage of justice and in that the nature of the
prosecution is such that it is unreasonable to expect
adequate trial preparation within the time limits prescribed
by the Speedy Trial Act.
a. The discovery in this matter consists of tens of thousands
of pages of records and documents from numerous sources.
Several federal agencies investigated this matter, and the
conduct alleged in the Indictment overlaps with various other
matters of investigative activity.
b. The fraud and bribery scheme alleged in the Indictment is
complex because it involves the records and activity of
federal and state governmental entities and financial records
and data that will take significant time for the defense to
review and adequately prepare for pretrial motions and trial.
c. The parties acknowledge there is a possibility for a
superseding indictment to be returned alleging additional
parties stipulate that they seek to vacate the current trial
setting for this matter of February 26, 2018, and set the
matter for a firm trial setting in or about November 5, 2018.
The United States anticipates, at this time, it will need no
more than three weeks to present its case-in-chief.