United States District Court, D. Nevada
J. YAMPOLSKY, ESQ. Attorney for Defendant Goldsby
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
HONORABLE CAM FERENBACH, UNITED STATES MAGISTRATE JUDGE.
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.
FURTHER STIPULATED AND AGREED that the Government shall have
to and including February 16, 2018, within which to file any
and all responsive pleadings.
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.
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
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