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United States v. Smith

United States District Court, D. Nevada

May 25, 2018

UNITED STATES OF AMERICA, Plaintiff,
v.
JOEL SHANNON SMITH, Defendant.

          GENTILE CRISTALLI MILLER ARMENI SAVARESE PAOLA M. ARMENI Nevada Bar No. 8357 Attorney for Defendant, JOEL SHANNON SMITH

          DAYLE ELIESON UNITED STATES ATTORNEY DISTRICT OF NEVADA JARED GRIMMER Assistant United States Attorney Attorneys for Plaintiff, UNITED STATES OF AMERICA

          STIPULATION AND ORDER TO CONTINUE MOTIONS DEADLINES ONLY (THIRD REQUEST)

          JENNIFER A DORSEY UNITED STATES DISTRICT COURT JUDGE

         IT IS HEREBY STIPULATED by and between Joel Shannon Smith, Defendant, by and through his counsel, Paola M. Armeni, Esq., of the law firm of Gentile Cristalli Miller Armeni Savarese and the Plaintiff, United States of America, by and through Dayle Elieson, United States Attorney, and, Jared Grimmer, Assistant United States Attorney, that the pretrial motion deadline date currently scheduled for May 25, 2018, be vacated and extended in accordance with the parties' agreement below.

         IT IS FURTHER STIPULATED AND AGREED that the parties herein shall have up to and including June 11, 2018, within which to file any and all pretrial motions and notice of defense.

         IT IS FURTHER STIPULATED AND AGREED that the parties herein shall have up to and including July 6, 2018, within which to file any and all responsive pleadings.

         IT IS FURTHER STIPULATED AND AGREED that the parties herein shall have up to and including July 13, 2018, within which to file any and all replies to dispositive motions.

         This Stipulation is entered into for the following reasons:

1. The current pretrial motion deadline is May 25, 2018.
2. Defense counsel needs additional time to make a final determination if any pretrial motions are warranted.
3. Both defense counsel and counsel for the Government will be out of the office due to prior scheduled conflicts during the time frame that responses and replies are currently due.
4. The extension will allow the parties to meet the deadlines set without an additional request for more time.
5. Mr. Joel Shannon Smith has appeared in this case is in custody and, along with the government, agree to a continuance.
6. The additional time requested herein is not sought for purposes of delay and the denial of this request for a continuance could result in a miscarriage of justice; 7. For all the above-stated reasons, the ends of justice would be best ...

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