Opinion
2:22-cr-00278-CDS-DJA-1
10-06-2023
UNITED STATES OF AMERICA, Plaintiff, v. CHRISTIAN SALVADOR CONTRERAS, Defendant.
TANASI LAW OFFICES RICHARD E. TANASI, ESQ. Nevada State Bar No. 9699 Attorney for Christian Salvador Contreras
TANASI LAW OFFICES RICHARD E. TANASI, ESQ. Nevada State Bar No. 9699 Attorney for Christian Salvador Contreras
STIPULATION FOR EXTENSION OF TIME TO FILE REPLY TO GOVERNMENT'S RESPONSE [42] TO MOTION TO COMPEL [33]
HONORABLE DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the United States of America, and Richard Tanasi, appointed counsel for Defendant Christian Salvador Contreras, that the defendant's deadline to file his Reply to Government's Response [42] to Motion to Compel United States Marshals to Provide Adequate Medical Care [33], currently set for October 6, 2023 [48], be continued to at least thirty (30) days.
This Stipulation is entered into for the following reasons:
1) Counsel Richard Tanasi was appointed to the case on August 15, 2023.
2) The government filed its Response on August 17, 2023.
3) The parties are attempting to resolve the issue presented. To that end, the defense has engaged a dental expert, who requires a dental x-ray to evaluate the defendant's medical/dental condition. The parties need time to explore the viability of an x-ray. As such, defense counsel requires additional time to file a Reply.
4) The defendant is incarcerated and does not object to this request.
5) The parties agree to the extension.
6) The additional time requested herein is not sought for purposes of delay.
ORDER
Based on the Stipulation of counsel and good cause appearing, IT IS THEREFORE ORDERED that the Defendant's deadline to file its Reply to Defendant's [33] Motion to Compel United States Marshals to Provide Adequate Medical Care, currently set for August October 6, 2023, is reset to November 6, 2023.