Filed: Jul. 22, 2019
Latest Update: Jul. 22, 2019
Summary: Joint Stipulation to Continue Government's Response to Defendant's Motion to Dismiss (ECF No. 26), and Defendant's Reply (Second Request) NANCY J. KOPPE , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Jared L. Grimmer, Assistant United States Attorney, counsel for the United States of America, Rene L. Valladares, Federal Public Defender, and Andrew Wong, Assistant Federal Public Defender, counsel for Julio Cesar Gar
Summary: Joint Stipulation to Continue Government's Response to Defendant's Motion to Dismiss (ECF No. 26), and Defendant's Reply (Second Request) NANCY J. KOPPE , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Jared L. Grimmer, Assistant United States Attorney, counsel for the United States of America, Rene L. Valladares, Federal Public Defender, and Andrew Wong, Assistant Federal Public Defender, counsel for Julio Cesar Garc..
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Joint Stipulation to Continue Government's Response to Defendant's Motion to Dismiss (ECF No. 26), and Defendant's Reply
(Second Request)
NANCY J. KOPPE, Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Jared L. Grimmer, Assistant United States Attorney, counsel for the United States of America, Rene L. Valladares, Federal Public Defender, and Andrew Wong, Assistant Federal Public Defender, counsel for Julio Cesar Garcia-Cuevas, that the government's response to defendant's motion to dismiss (ECF No. 26) currently due on Tuesday, July 23, 2019, be vacated and continued to July 31, 2019, with defendant's corresponding reply due on August 7, 2019.
This Stipulation is entered into for the following reasons:
1. Government counsel continues to need additional time to properly respond to defendant's motion, to include researching the issues raised by the defendant.
2. Government counsel has requested a copy of records from the defendant's Immigration Court proceeding, and has not yet received these records. These records may be dispositive of the current motion.
3. Denial of this request for continuance could result in a miscarriage of justice.
4. This is the second request for continuance of the government response to defendant's motion to dismiss.
DATED this 22nd day of July, 2019.
RENE L. VALLADARES NICHOLAS A. TRUTANICH
Federal Public Defender United States Attorney
By /s/ Andrew Wong By /s/ Jared L. Grimmer
ANDREW WONG JARED L. GRIMMER
Assistant Federal Public Defender Assistant United States Attorney
IT IS THEREFORE ORDERED that the government's response to defendant's motion to dismiss (ECF No. 26) currently due on Tuesday, July 23 2019, be vacated and continued to July 31, 2019, with defendant's corresponding reply due on August 7, 2019.