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United States v. Buenrostro

United States District Court, D. Nevada

April 4, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
JOSE BUENROSTRO, Defendant.

          NICHOLAS A. TRUTANICH United States Attorney

          ALEXANDRA MICHAEL Assistant United States Attorney

          CRANE 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)

         IT IS 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.

         This stipulation is entered for the following reasons:

         1. The government needs additional time to research and review Defendant's Motion to Suppress and file a response.

         2. Two of the potential witnesses, for the evidentiary hearing, probation officers MacDiermid and Thompson, are in training from April 9, 2019 through April 11, 2019.

         3. The third potential witness for the evidentiary hearing, retired DEA Agent Mabey, will be out of the state from May 12, 2019 - May 22, 2019.

         4. The 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.

         5. The parties agree to the continuance.

         6. The defendant is currently in custody and agrees to the continuance.

         7. For the reasons stated above, the ends of justice would best be served by a continuance of the government's response deadline and evidentiary hearing.

         8. The additional time requested by this stipulation is made in good ...


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