Opinion
2:21-cr-184-JCM-NJK
11-02-2022
HOFLAND & TOMSHECK, Joshua Tomsheck, Esq., State Bar of Nevada No. 009210, Attorney for Defendant. JASON M. FRIERSON, United States Attorney. DANIEL SCHIESS, ESQ., Assistant United States Attorney.
HOFLAND & TOMSHECK, Joshua Tomsheck, Esq., State Bar of Nevada No. 009210, Attorney for Defendant.
JASON M. FRIERSON, United States Attorney.
DANIEL SCHIESS, ESQ., Assistant United States Attorney.
STIPULATION TO ALLOW DEFENDANT TO TRAVEL
IT IS HEREBY STIPULATED AND AGREED, by and between JASON M. FRIERSON, United States Attorney, and DANIEL SCHIESS, ESQ., Assistant United States Attorney, counsel for the United States of America, and JOSHUA TOMSHECK, ESQ., counsel for Defendant, OFIR FRIEDEN, be allowed to travel from California to Las Vegas for purposes of meeting with undersigned counsel on or about November 9, 2022.
This stipulation is entered into for the following reasons:
1. This is the first request of this nature.
2. Defense Counsel has scheduled an in-person/in-office meeting with the Defendant to review the discovery and further prepare the matter for resolution. Moreover, Defense counsel and the Assistant United States Attorney have scheduled an in-person meeting with Defendant for purposes of potential negotiation of Defendant's case.
3. Defendant has been in contact with his pre-trial services officer about this travel request and was informed the conditions of his pre-trial release are only allowed for purposes of Court appearances. Further, Defendant was instructed by his pretrial services officer that he should have Defense counsel seek Court approval for the instant request.
4. The parties agree that the Defendant should be permitted to travel to Las Vegas, NV for the purposes outlined herein.
ORDER
Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:
1. This is the first request of this nature.
2. Defense Counsel has scheduled an in-person/in-office meeting with the Defendant to review the discovery and further prepare the matter for resolution. Moreover, Defense counsel and the Assistant United States Attorney have scheduled an in-person meeting with Defendant for purposes of potential negotiation of Defendant's case.
3. Defendant has been in contact with his pre-trial services officer about this travel request and was informed the conditions of his pre-trial release are only allowed for purposes of Court appearances. Further, Defendant was instructed by his pretrial services officer that he should have Defense counsel seek Court approval for the instant request.
4. The parties agree that the Defendant should be permitted to travel to Las Vegas, NV for the purposes outlined herein.
ORDER
IT IS THEREFORE ORDERED, that Defendant, OFIR FRIEDEN, shall be granted permission to travel to Las Vegas, Nevada between on Monday November 7, 2022 and Thursday November 10, 2022 (including travel days) to meet with his counsel and counsel for the Government for purposes of potential negotiation of his pending case.