Opinion
2:21-mj-00640-NJK
04-01-2022
UNITED STATES OF AMERICA, Plaintiff, v. JEFFREY PATTERSON, Defendant.
RENE L. VALLADARES Federal Public Defender Nevada State Bar No. 11479 JOANNE L. DIAMOND Assistant Federal Public Defender Attorney for Jeffrey Patterson RENE L. VALLADARES, Federal Public Defender CHRISTOPHER CHIOU, Acting United States Attorney JOANNE L. DIAMOND, Assistant Federal Public Defender K. NICHOLAS PORTZ, Assistant United States Attorney
RENE L. VALLADARES Federal Public Defender Nevada State Bar No. 11479 JOANNE L. DIAMOND Assistant Federal Public Defender Attorney for Jeffrey Patterson
RENE L. VALLADARES, Federal Public Defender
CHRISTOPHER CHIOU, Acting United States Attorney
JOANNE L. DIAMOND, Assistant Federal Public Defender
K. NICHOLAS PORTZ, Assistant United States Attorney
STIPULATION TO CONTINUE PRELIMINARY HEARING (FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou, Acting United States Attorney, and K. Nicholas Portz, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Joanne L. Diamond, Assistant Federal Public Defender, counsel for Jeffrey Patterson, that the Preliminary Hearing currently scheduled on April 14, 2022 at 4:00 p.m., be vacated and continued to a date and time convenient to the Court, but no sooner than thirty (30) days.
This Stipulation is entered into for the following reasons:
1. The parties require additional time to discuss the potential for a Pre-Indictment negotiation.
2. Counsel for the defendant will require additional time to review and investigate discovery and meet with the client to discuss the details prior to proceeding.
3. Defendant is incarcerated and does not object to a continuance.
4. The parties agree to the continuance.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
6. Additionally, denial of this request for continuance could result in a miscarriage of justice. The additional time requested by this Stipulation is excludable in computing the time within which the trial herein must commence pursuant to the Speedy Trial Act, Title 18, United States Code, Section 3161(h)(7)(A), considering the factors under Title 18, United States Code, Section 3161 (h)(7)(B)(i), (iv).
This is the first request for continuance filed herein.
ORDER
Based on the Stipulation of counsel and good cause appearing, IT IS THEREFORE ORDERED that the Preliminary Hearing currently scheduled on April 14, 2022 at the hour of 4:00 p.m., be vacated and continued to May 18, 2022, at 4:00 p.m.