United States District Court, D. Nevada
NICHOLAS A. TRUTANICH United States Attorney District of
Nevada Nevada Bar No. 13644 PATRICK BURNS Nevada Bar No.
11779 Assistant United States Attorney Representing the
United States of America
RICHARD WRIGHT, ESQ. GEORGE KELESIS, ESQ. Counsel for
STIPULATION TO CONTINUE BRIEFING SCHEDULE ON TAX LOSS
JENNIFER A. DORSEY, UNITED STATES DISTRICT COURT JUDGE
hereby stipulated and agreed, by and between Nicholas A.
Trutanich, United States Attorney, through Patrick Burns,
Assistant United States Attorney, and Richard Wright, Esq.,
and George Kelesis, Esq., counsel for Defendant Ramon Desage,
that the deadline for the government's reply brief,
currently due on May 10, 2019, be continued to May 31, 2019,
or a date thereabouts acceptable to the Court. .
Stipulation is entered into for the following reasons:
February 5, 2019, after the evidentiary hearing in this
matter and deciding a subsequent motion, the Court set a
briefing schedule on the tax loss to be used in sentencing
Defendant Desage. The government's opening brief
regarding tax loss was filed on March 29, 2019. Desage filed
his response brief on April 26, 2019. The government's
reply brief is currently due on May 10, 2019.
the government and Desage have each requested a continuance
of the briefing schedule previously.
granting the last continuance, the Court advised that no
further extensions would be granted.
government submits that special circumstances warrant one
additional short continuance so the briefing may be completed
in a meaningful fashion.
Government counsel is currently set to begin trial in United
States v. Craig P. Orrock, No. 2:16-cr-00111-JAD-CWH.
Calendar call was held in that case yesterday, May 2, 2019,
at which both parties announced ready for trial and United
States District Court Judge Jennifer A. Dorsey ordered the
matter to proceed to trial as scheduled. The case is a
complicated tax crime prosecution and trial will begin on May
7, 2019. The defendant, a former IRS attorney appearing pro
se, is expected to put on a case-in-chief and it appears
likely that the trial may extend to or through May 15, 2019.
to extensive briefing in the Orrock case, and undersigned
government counsel's role as the only AUSA prosecuting
Desage's case, continuity of government counsel requires
a short final continuance of the briefing schedule to May 31,
2019, or a date thereabouts acceptable to the Court.
Counsel for Desage do not oppose this request.
request is made in good faith and not for purposes of delay.