JOINT STIPULATION TO CONTINUE MOTIONS DEADLINES

(Fourth Request)

RICHARD F. BOULWARE, II, District Judge.

IT IS HEREBY STIPULATED AND AGREED, between the United States of America, through its attorneys, DAYLE ELIESON, United States Attorney, and RICHARD (TONY) ANTHONY LOPEZ and ALEXANDRA MICHAEL, Assistant United States Attorneys, and the Defendant, CAMERON JAMES KENNEDY, through his counsel, RUSSELL E. MARSH, ESQUIRE, and MONTI JORDANA LEVY, ESQUIRE, WRIGHT STANISH & WINCKLER, that the current schedule for filing and responding to pretrial motions be vacated and extended for one week. This stipulation is entered into for the following reasons:

1. By Order of the Court dated August 21, 2018, any pretrial motions are now due on September 20, 2018; responses to any motions shall be filed within 14 days from the date of service of the motions; and any replies may be filed within 7 days of service of the responses.

2. The parties require additional time to conduct legal and factual research and to prepare any motions.

3. The parties are engaged in plea negotiations in an effort to resolve this matter without the need for trial or further motions.

4. One of Mr. Kennedy's defense counsel, Russell E. Marsh, has been occupied with preparing an appellate brief in United States v. Edward Levine, Case No 18-10110 (Ninth Circuit), which was filed on September 14, 2018.

5. The parties agree that the new motions schedule shall be as follows: The parties shall have until September 27, 2018, to file any pretrial motions and notices of defenses. The parties shall have until October 11, 2018, to file any responsive pleadings to these motions. Any replies shall be due on or before October 18, 2018.

6. This is the parties' fourth request to continue the motions schedule in this case, following two previous stipulations and a motion on this issue. Mr. Kennedy is in custody and agrees with this request.

WHEREFORE, the United States of America, and the Defendant, Cameron James Kennedy, request that the motions schedule be continued for one week as set forth above.

ORDER

Based upon the pending Stipulation of counsel and good cause appearing, the Court hereby grants the joint request and extends the motions schedule as follows: The parties shall have until September 27, 2018, to file any pretrial motions and notices of defenses. The parties shall have until October 11, 2018, to file any responsive pleadings to these motions. Any replies shall be due on or before October 18, 2018.

SO ORDERED.