Filed: Nov. 19, 2015
Latest Update: Nov. 19, 2015
Summary: STIPULATION AN ORDER TO EXTEND BRIEFING SCHEDULE RE PRETRIAL MOTIONS ANTHONY W. ISHII , Senior District Judge . THE PARTIES HEREBY STIPULATE, through their respective attorneys of record, Assistant United States Attorney Brian W. Enos, counsel for the government, and Gary Huss, Counsel for Defendant Michael Brandon Kiper ("defendant"), that this action's briefing schedule regarding pretrial motions be extended as set forth below. Notably, the parties do not ask at this time that the current
Summary: STIPULATION AN ORDER TO EXTEND BRIEFING SCHEDULE RE PRETRIAL MOTIONS ANTHONY W. ISHII , Senior District Judge . THE PARTIES HEREBY STIPULATE, through their respective attorneys of record, Assistant United States Attorney Brian W. Enos, counsel for the government, and Gary Huss, Counsel for Defendant Michael Brandon Kiper ("defendant"), that this action's briefing schedule regarding pretrial motions be extended as set forth below. Notably, the parties do not ask at this time that the current ..
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STIPULATION AN ORDER TO EXTEND BRIEFING SCHEDULE RE PRETRIAL MOTIONS
ANTHONY W. ISHII, Senior District Judge.
THE PARTIES HEREBY STIPULATE, through their respective attorneys of record, Assistant United States Attorney Brian W. Enos, counsel for the government, and Gary Huss, Counsel for Defendant Michael Brandon Kiper ("defendant"), that this action's briefing schedule regarding pretrial motions be extended as set forth below. Notably, the parties do not ask at this time that the current January 4, 2016 trial confirmation hearing/hearing on pretrial motions or January 19, 2016 trial date likewise be continued.
Existing Dates Requested Extension Dates
1. Pretrial Motions
a. Filing of motions — November 23, 2015 December 14, 2015
b. Filing of oppositions — December 14, 2015 December 23, 2015
c. Filing of Reply Briefs — December 21, 2015 December 30, 2015
2. Trial Confirmation Hearing/ — January 4, 2016 Unchanged
Hearing on Pretrial Motions
3. Trial — January 19, 2016 (8:30 a.m.) Unchanged
The parties base this stipulation on good cause. In short, they ask the court to grant their joint request for an extended briefing schedule regarding pretrial motions, as set forth above, so they can continue focusing their efforts toward resolving this matter prior to trial. More specifically, within the past month, the parties have thoroughly analyzed various aspects of the evidence in this case, and have engaged in extensive negotiations about this evidence and how it impacts a potential resolution of this case. On this end, counsel for the government has also sought and obtained both U.S. Probation's and the U.S. Sentencing Commission's input regarding how to properly calculate certain Sentencing Guidelines relevant to a potential resolution of this case, and has shared that input with defense counsel during the negotiations process.
As a result of the parties' above efforts, the government expects to have a draft plea agreement submitted to defense counsel within the next day or two (it is currently going through the approval process within the government's offices). It thereafter intends to keep the plea offer open until roughly a week prior to the above requested December 14, 2015 motion filing deadline.
For the above stated reasons, the stipulated continuance will conserve time and resources both for the parties and the court, and the delay resulting from this continuance shall be excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A).
ORDER
IT IS SO ORDERED.
