STIPULATION TO CONTINUE PRETRIAL MOTION DEADLINES

(First Request)

CAM FERENBACH, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Phillip N. Smith, Jr., Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Monique Kirtley, Assistant Federal Public Defender, counsel for Demetrick Lee Tellis, II, that the previously ordered deadline for filing of pretrial motions be vacated and that the parties herein shall have to and including March 29, 2019, within which to file the Defendant's pretrial motions currently due March 15, 2019.

IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including April 12, 2019, to file any and all responsive pleadings, currently due March 29, 2019.

IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including April 19, 2019, to file any and all replies to dispositive motions, currently due April 5, 2019.

The Stipulation is entered into for the following reasons:

1. Counsel for the defendant needs additional time to complete necessary research regarding a possible pretrial motion and time to discuss the results of the research with her client.

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 receive and review additional discovery materials and to be able to effectively complete investigation of this case.

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

This is the first stipulation to continue filed herein.

FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER

FINDINGS OF FACT

Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:

1. Counsel for the defendant needs additional time to complete necessary research regarding a possible pretrial motion and time to discuss the results of the research with her client.

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 receive and review additional discovery materials and to be able to effectively complete investigation of this case.

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