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United States v. Zarate

United States District Court, D. Nevada

May 29, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
GERARDO JAVIER ZARATE, and GRISELDA NEGRETE ZARATE, Defendant.

          NICHOLAS A. TRUTANICH United States Attorney

          KATHRYN NEWMAN, AFPD Counsel for Gerardo Javier Zarate

          ALLISON REESE Assistant United States Attorney

          TODD LEVENTHAL Counsel for Griselda Negrete Zarate

          STIPULATION TO CONTINUE THE PRELIMINARY HEARING (FIRST REQUEST)

          THE HONORABLE NANCY J. KOPPE, UNITED STATES MAGISTRATE JUDGE

         IT IS HEREBY STIPULATED AND AGREED, by and between NICHOLAS A. TRUTANICH, United States Attorney, and ALLISON REESE, Assistant United States Attorney, counsel for the United States of America, KATHRYN NEWMAN, Assistant Federal Public Defender, counsel for Defendant GERARDO JAVIER ZARATE, and TODD LEVENTHAL, counsel for Defendant GRISELDA NEGRETE ZARATE, that the preliminary hearing date in the above-captioned matter, currently scheduled for May 31, 2019, at 4:00 pm, be vacated and continued for thirty (30) days, to a date and time to be set by this Honorable Court.

         This stipulation is entered into for the following reasons:

         1. The Government needs additional time to produce relevant discovery to Defense Counsel.

         2. Defense Counsel needs additional time to review the discovery, conduct additional investigation, and confer with the Defendants about how they would like to proceed.

         3. The parties agree to the continuance.

         4. Defendant GERARDO ZARATE is out of custody and does not object to the continuance.

         5. Defendant GRISELDA ZARATE is in ICE custody but does not object to the continuance.

         6. Additionally, denial of this request for continuance could result in a miscarriage of justice.

         7. The additional time requested herein is not sought for purposes of delay, but to allow for a potential ...


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