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United States v. Mejia-Torres

United States District Court, D. Nevada

April 5, 2018

UNITED STATES OF AMERICA, Plaintiff,
v.
JESUS MEJIA-TORRES, Defendant.

          RENE L. VALLADARES Federal Public Defender BRIAN PUGH Assistant Federal Public Defender

          DAYLE ELIESON United States Attorney

          KIMBERLY M. FRAYN Assistant United States Attorney

          STIPULATION TO CONTINUE MOTION DEADLINES ORDER

         IT IS HEREBY STIPULATED AND AGREED, by and between Dayle Elieson, United States Attorney, and Kimberly M. Frayn, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel for Jesus Mejia-Torres, to continue motion deadlines for thirty (30) days.

         IT IS STIPULATED AND AGREED, that the parties herein shall have to and including May 2, 2018, 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 May 16, 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 May 23, 2018, to file any and all replies to dispositive motions.

         The Stipulation is entered into for the following reasons:

1. Counsel for the defendant needs additional time to conduct investigation in this case in order to determine whether there are any pretrial issues that must be litigated and whether the case will ultimately go to trial or will be resolved through negotiations.
2. The defendant is incarcerated and does not object to the continuance.
3. The parties agree to the continuance.
4. 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 complete investigation of the discovery materials provided.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice. The additional time requested by this Stipulation is excludable in computing the time within which the trial herein must commence pursuant to the Speedy Trial Act, Title 18, United States Code, Section 3161(h)(7)(A), considering ...

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