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United States v. Suarez

United States District Court, D. Nevada

January 7, 2020

UNITED STATES OF AMERICA, Plaintiff,
v.
JESUS SUAREZ, Defendant.

          RENE L. VALLADARES Federal Public Defender

          ROBERT E. O'BRIEN Assistant Federal Public Defender

          NICHOLAS A. TRUTANICH United States Attorney

          STEPHANIE IHLER Assistant United States Attorney

          STIPULATION TO CONTINUE MOTION DEADLINES (SECOND REQUEST)

         IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Stephanie Ihler, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Robert E. O'Brien, Assistant Federal Public Defender, counsel for Jesus Suarez, that the pretrial motion deadline be continued sixty (60) days.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including February 21, 2020, to file any and all pretrial motions and notice of defense, currently due December 23, 2019.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including March 6, 2020, to file any and all responsive pleadings, currently due January 6, 2020.

         IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including March 13, 2020, to file any and all replies to dispositive motions, currently due January 13, 2020.

         1. Counsel for the defendant recently received additional discovery. Additional time is needed to conduct investigation in this case in order to determine whether there are any pretrial issues that must be litigated and whether the case will ultimately go to trial or will be resolved through negotiations.

         2. The defendant is incarcerated and does not object to the continuance.

         3. The parties agree to the continuance.

         4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to be able to effectively and complete investigation of the discovery materials provided.

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


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