United States District Court, D. Nevada
NICHOLAS A. TRUTANICH United States Attorney
ALEXANDRA MICHAEL Assistant United States Attorney
POMERANTZ Counsel for Defendant JOSE BUENROSTRO
STIPULATION TO CONTINUE GOVERNMENT'S RESPONSE TO
DEFENDANT'S MOTION TO SUPPRESS AND EVIDENTIARY HEARING ON
DEFENDANT'S MOTION TO SUPPRESS (SECOND REQUEST)
HEREBY STIPULATED AND AGREED, by and between, the United
States of America, through the undersigned, together with
Crane Pomerantz, Esq., counsel for defendant JOSE BUENROSTRO,
that the Government's Response to Defendant's Motion
to Suppress currently due on April 4, 2019, be vacated and
continued for three weeks, with a new due date of April 24,
2019. Additionally, the Evidentiary Hearing on
Defendant's Motion to Suppress currently set for April
10, 2019 at 9:30 a.m. also be vacated and continued for a
time convenient to this Court but no sooner than four weeks,
May 6, 2019, from that date.
stipulation is entered for the following reasons:
government needs additional time to research and review
Defendant's Motion to Suppress and file a response.
of the potential witnesses, for the evidentiary hearing,
probation officers MacDiermid and Thompson, are in training
from April 9, 2019 through April 11, 2019.
third potential witness for the evidentiary hearing, retired
DEA Agent Mabey, will be out of the state from May 12, 2019 -
May 22, 2019.
assigned AUSA begins trial in the case of United States
v. Thomas et al. 15-cr-62-APG-CWH on April 22, 2019 and
it is set to last until May 3, 2019.
parties agree to the continuance.
defendant is currently in custody and agrees to the
the reasons stated above, the ends of justice would best be
served by a continuance of the government's response
deadline and evidentiary hearing.
additional time requested by this stipulation is made in good