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United States v. Barrientos

United States District Court, D. Nevada

September 3, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
GILBERTO G. BARRIENTOS, Defendant.

          NICHOLAS A. TRUTANICH U.S. ATTORNEY ALLISON REESE Assistant United States Attorney

          LAW OFFICE OF DAN M. WINDER, PC, DAN M. WINDER Nevada State Bar No. 001569

          STIPULATION TO CONTINUE PRE-TRIAL MOTIONS

          RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE.

         Certification: This stipulation is timely filed.

         IT 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.

         This 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 case.
3. The parties agree to the continuance sought herein.
4. The Defendant does not object to the continuance in this matter.
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 ...

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