Filed: Jul. 22, 2019
Latest Update: Jul. 22, 2019
Summary: STIPULATION FOR EXTENSION OF TIME (First Request) NANCY J. KOPPE , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the United States of America, and Todd Leventhal, counsel for Defendant GRISELDA NEGRETE ZARATE, that the date for the Government to file a response to the Defendant's Motion to Dismiss (ECF No. 37) be extended for three days, specifically to
Summary: STIPULATION FOR EXTENSION OF TIME (First Request) NANCY J. KOPPE , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the United States of America, and Todd Leventhal, counsel for Defendant GRISELDA NEGRETE ZARATE, that the date for the Government to file a response to the Defendant's Motion to Dismiss (ECF No. 37) be extended for three days, specifically to J..
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STIPULATION FOR EXTENSION OF TIME
(First Request)
NANCY J. KOPPE, Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the United States of America, and Todd Leventhal, counsel for Defendant GRISELDA NEGRETE ZARATE, that the date for the Government to file a response to the Defendant's Motion to Dismiss (ECF No. 37) be extended for three days, specifically to July 26, 2019.
This stipulation is entered for the following reasons:
1. The Defendant's Motion was filed and served on July 9, 2019. See ECF No. 37. The Government's response deadline is presently July 23, 2019.
2. Counsel for the Government is in need of additional time to conduct additional investigation and research to adequately respond to the Defendant's motion.
3. The additional time requested herein is not sought for purposes of delay, but to allow counsel for the Government time to adequately respond to the Defendant's motion.
4. Additionally, denial of this request for continuance could result in a miscarriage of justice.
5. This is the first stipulation filed herein to continue the Government's response deadline.
DATED: July 22, 2019
Respectfully submitted,
NICHOLAS A. TRUTANICH
United States Attorney
/s/ Allison Reese /s/ Todd Leventhal
________________________________ ________________________________
ALLISON REESE TODD LEVENTHAL
Assistant United States Attorney Counsel for Defendant
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. The Defendant's Motion was filed and served on July 9, 2019. See ECF No. 37. The Government's response deadline is presently July 23, 2019.
2. Counsel for the Government is in need of additional time to conduct further investigation and research to adequately respond to the Defendant's motion.
3. The additional time requested herein is not sought for purposes of delay, but to allow counsel for the Government time to adequately respond to the Defendant's motion.
4. Additionally, denial of this request for continuance could result in a miscarriage of justice.
5. This is the first stipulation filed herein to continue the Government's response deadline.
For all of the above-stated reasons, the ends of justice would best be served by a continuance of the Government's response deadline.
CONCLUSIONS OF LAW.
The additional time requested herein is not sought for purposes of delay, but to allow the Government with adequate time to respond to the Defendant's motion. The failure to grant said continuance would likely result in a miscarriage of justice.
ORDER
IT IS THEREFORE ORDERED, that the previously-scheduled response deadline for the Government to respond to the Defendant's Motion to Dismiss is extended until July 26, 2019.
