JOINT REQUEST AND ORDER TO MODIFY SCHEDULE FOR FILING TRIAL DOCUMENTS

MORRISON C. ENGLAND, Jr., Chief District Judge.

This matter is presently set for a jury trial scheduled to begin on March 30, 2015. A Trial Confirmation Hearing (TCH) was advanced by one week to February 19, 2015. At the TCH, the Court denied defendant's request for new counsel. The Court further set deadlines for filing motions in limine, proposed voir dire questions, trial briefs, verdict forms, proposed jury instructions, and witness and exhibit lists, and for the parties to exchange binders containing trial exhibits.

Following the TCH, the parties continued to engage in settlement discussions and reached a proposed resolution for a specific sentence pursuant to Rule 11(c)(1)(C) of the Federal Rules of Criminal Procedure. The government promptly prepared a written plea agreement incorporating the terms of the proposed resolution. The parties selected the Court's next available criminal calendar date — Thursday, March 12, 2015 — as the time and place for the change of plea hearing to take place. Defendant thereafter rejected the plea agreement by insisting on a reduction in the previously-negotiated specific sentence in the plea agreement. This rejection occurred on March 9, 2015 — the date upon which some of the relevant trial documents were due to be filed.

During the period when it appeared that a resolution had been reached in the case, counsel for both sides suspended efforts to meet and confer regarding stipulations as to facts and resolution of potential evidentiary issues in this case. Counsel for both sides believe that a brief extension of the filing deadlines in this case will facilitate the resolution of some of these matters and the elimination of some issues needed to be resolved through formal motions. The parties therefore jointly request a modification of the time for filing trial documents in the case as follows:

The parties believe that the brief extension will facilitate their continued cooperation in narrowing the number of issues to be addressed by the Court. Assistant U.S. Attorney Jill Thomas has reviewed this proposed order and authorized Todd Leras to sign it on her behalf.

ORDER

BASED ON THE REPRESENTATIONS AND JOINT REQUEST OF THE PARTIES, it is hereby ordered that the deadlines for filing of trial documents in the case is modified as set forth in the joint request. Proposed voir dire questions, motions in limine, proposed jury instructions, witness lists, proposed verdict forms, exhibit lists, and trial briefs to be filed by March 18, 2015. Responses to motions in limine to be filed by March 20, 2015. Exchange of exhibits containing trial exhibits to occur by March 27, 2015.

IT IS SO ORDERED.