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United States v. Franklin

United States District Court, D. Nevada

January 4, 2018

UNITED STATES OF AMERICA, Plaintiff,
v.
MARQUIS LAMAR FRANKLIN, Defendant.

          RENE L. VALLADARES Federal Public Defender

          STEVEN W. MYHRE Acting United States Attorney

          NISHA BROOKS-WHITTINGTON Assistant Federal Public Defender

          PHILLIP N. SMITH, JR. Assistant United States Attorney

          STIPULATION TO CONTINUE MOTION DEADLINES

         ORDER

         IT IS HEREBY STIPULATED AND AGREED, by and between Steven W. Myhre, Acting United States Attorney, and Phillip N. Smith, Jr., Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Nisha Brooks-Whittington, Assistant Federal Public Defender, counsel for Marquis Lamar Franklin, that the parties herein shall have to and including February 5, 2018, by the hour of 4:00 p.m., within which to file any and all pretrial motions and notices of defense.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including February 19, 2018, to file any and all responsive pleadings.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including February 26, 2018, to file any and all replies to dispositive motions.

         The Stipulation is entered into for the following reasons:

         1. Undersigned counsel was in trial from December 19, 2017 to December 21, 2017 in United States v. Hessiani, No. 2:16-cr-00320-LRH-VCF, and then out of the office from December 22, 2017 until January 2, 2018.

         2. Counsel needs additional time to discuss the case with her client and determine whether any pretrial motions will be filed.

         3. The defendant is incarcerated and does not object to the continuance.

         4. The parties agree to the continuance.

         5. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to be able to effectively and ...


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