Opinion
2:96-cr-00046-KJD-PAL
02-01-2023
UNITED STATES OF AMERICA, Plaintiff, v. FERDINAND RICHARD BALCAR, JR., Defendant.
RENE L. VALLADARES Federal Public Defender HEIDI OJEDA Assistant Federal Public Defender JASON M. FRIERSON United States Attorney ROBERT ELLMAN Assistant United States Attorney
RENE L. VALLADARES Federal Public Defender
HEIDI OJEDA Assistant Federal Public Defender
JASON M. FRIERSON United States Attorney
ROBERT ELLMAN Assistant United States Attorney
STIPULATION TO CONTINUE SUPPLEMENT'S DEADLINE TO MOTION FOR COMPASSIONATE RELEASE (FOURTH REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Jason Freirson, United States Attorney, and Robert Ellman, 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 February 7, 2023 and the Government will have until February 21, 2023, to file a response.
This Stipulation is entered into for the following reasons:
1. Counsel for defense needs additional time to gather information to supplement Mr. Balcar's request for compassionate release.
2. The government does not oppose this request.
3. Mr. Balcar does not object to the continuance.
4. The additional time requested by the stipulation is made in good faith and not for purposes of delay.
This is the fourth 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 February 7, 2023, and the Government will have until February 21, 2023, to file a response.