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United States v. Goldsby

United States District Court, D. Nevada

January 24, 2018

UNITED STATES OF AMERICA Plaintiff,
v.
JASON GOLDSBY, RUDY REDMOND, and KAILI TUALAU Defendants.

          MACE J. YAMPOLSKY, ESQ. Attorney for Defendant Goldsby

          OFFICE OF THE UNITED STATES ATTORNEY CRISTINA D. SILVA, ESQ. Attorney for Plaintiff

          MICHAEL MICELI, ESQ. Attorney for Defendant Redmond

          GABRIEL GRASSO, ESQ. Attorney for Defendant Tualau

          JOINT STIPULATION TO CONTINUE PRE-TRIAL MOTIONS

          HONORABLE CAM FERENBACH, UNITED STATES MAGISTRATE JUDGE.

         IT IS HEREBY STIPULATED AND AGREED, by and between Dayle Elieson, United States Attorney, District of Nevada, and by and through Cristina Silva and Frank J. Cuomou, Assistant United States Attorneys, representing the United States of America, and Mace J. Yampolsky, Esq., counsel for Defendant Jason Goldsby, Michael Miceli, Esq., counsel for Defendant Rudy Redmond, and Gabriel Grasso, Esq., counsel for Defendant5 Kaili Tualau that the Defendants shall have to and including February 2, 2018, within which to file pretrial motions.

         IT IS FURTHER STIPULATED AND AGREED that the Government shall have to and including February 16, 2018, within which to file any and all responsive pleadings.

         IT IS FURTHER STIPULATED AND AGREED that the Defendants shall have to and including, February 23, 2018, within which to file any and all replies to said motions.

         This Stipulation is entered into for the following reasons:

1. That a Stipulation to Continue Trial (Fifth Request) was filed on January 16, 2018 (ECF #84).
2. That the Stipulation to Continue Trial was silent as to the extension of the period for the filing of pretrial motions.
3. Counsel for Defendant Goldsby, Mace J. Yampolsky, Esq., was appointed in December of 2017. Additional time is needed for Mr. Yampolsky to review discovery in this matter.
4. Further, a Federal Grand Jury issued a superseding indictment on December 19, 2017, [sealed], and added additional charges against the Defendants, including a new ...

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