Opinion
2:96-cr-00046-KJD-PAL
12-02-2022
UNITED STATES OF AMERICA, Plaintiff, v. FERDINAND RICHARD BALCAR, JR., Defendant.
RENE L. VALLADARES Federal Public Defender Nevada State Bar No. 11479 HEIDI OJEDA Assistant Federal Public Defender Nevada State Bar No. 12223 Attorney for Ferdinand Richard Balcar, Jr. RENE L. VALLADARES, Federal Public Defender JASON M. FRIERSON, United States Attorney HEIDI OJEDA Assistant United States Attorney ELIZABETH WHITE Assistant Federal Public Defender
RENE L. VALLADARES Federal Public Defender Nevada State Bar No. 11479 HEIDI OJEDA Assistant Federal Public Defender Nevada State Bar No. 12223 Attorney for Ferdinand Richard Balcar, Jr.
RENE L. VALLADARES, Federal Public Defender
JASON M. FRIERSON, United States Attorney
HEIDI OJEDA Assistant United States Attorney
ELIZABETH WHITE Assistant Federal Public Defender
STIPULATION TO CONTINUE SUPPLEMENT'S DEADLINE TO MOTION FOR COMPASSIONATE RELEASE (THIRD REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Jason Freirson, United States Attorney, and Elizabeth White, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Heidi Ojeda, Assistant Federal Public Defender, counsel for Ferdinand Richard Balcar, Jr., request that the due date for Mr. Balcar's Supplement to Motion for Compassionate Release (ECF No. 249), be extended until January 31, 2023.
This Stipulation is entered into for the following reasons:
1. The Court previously granted the parties request for a stipulation to continue the supplement date. Unfortunately, due to a calendar error, counsel did not file by that date. Defendant's family recently reached out about the status of his case. Counsel then realized her mistake and contacted the government.
2. Counsel is in trial starting December 5, 2022 and is taking leave around the holidays. Counsel therefore requests this Court allow defense until January 31, 2023 to file a supplement.
3. The parties agree to the continuance.
4. Mr. Balcar does not object to the continuance.
5. The additional time requested by the stipulation is made in good faith and not for purposes of delay.
This is the third request for a continuance of the supplement deadline.
ORDER
IT IS THEREFORE ORDERED that upon consideration of Defendant's Request to Extend Deadline for filing his Supplement to Motion for Compassionate Release, that the Defendant's deadline to file his Supplement is extended until January 31, 2023, and the Government will have until February 14, 2023, to file a response.