United States District Court, D. Nevada
NICHOLAS A. TRUTANICH U.S. ATTORNEY ALLISON REESE Assistant
United States Attorney
OFFICE OF DAN M. WINDER, PC, DAN M. WINDER Nevada State Bar
STIPULATION TO CONTINUE PRE-TRIAL MOTIONS
RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE.
This stipulation is timely filed.
IS HEREBY STIPULATED by and between, ALLISON REESE,
Assistant United States Attorney, counsel for Plaintiff,
UNITED STATES OF AMERICA, Defendant, GILBERTO G. BARRIENTOS,
by and through his counsel DAN M. WINDER, ESQ., of the LAW
OFFICE OF DAN M. WINDER, PC, that the pre-trial motions in
this matter currently due by September 3, 2019, be continued
to September 16, 2019.
stipulation is entered into for the following reasons:
1. Counsel for Defendant requires additional time to review
the discovery provided by the Government, and to investigate
the Government's allegations as to their client.
2. In addition, there are ongoing negotiation discussions
between counsel for the Government and the defense and as
such, negotiations may obviate the need for a trial in this
3. The parties agree to the continuance sought herein.
4. The Defendant does not object to the continuance in this
5. The additional time requested herein is not sought for
purposes of delay.
6. Denial of this request for continuance could deny the
Defendants the opportunity to effectively prepare for trial
and/or result in a miscarriage of justice.
7. The additional time requested by this Stipulation is
excludable in computing the time within which the trial
herein must commence pursuant to the Speedy Trial Act, Title
18, United States Code, Section 3161(h)(7)(A) considering the
factors under ...