Opinion
2:21-cr-00235-APG-EJY
04-11-2022
UNITED STATES OF AMERICA, Plaintiff, v. HAROLD DAVID SOBEL, Defendant.
RENE L. VALLADARES Federal Public Defender NISHA BROOKS-WHITTINGTON Assistant Federal Public Defender CHRISTOPHER CHIOU Acting United States Attorney MINA CHANG Assistant United States Attorney GUSTAV W. EYLER Director U.S. Department of Justice MEREDITH BURNS HEALY Trial Attorneys WEI XIANG Trial Attorney
RENE L. VALLADARES Federal Public Defender
NISHA BROOKS-WHITTINGTON Assistant Federal Public Defender
CHRISTOPHER CHIOU Acting United States Attorney
MINA CHANG Assistant United States Attorney
GUSTAV W. EYLER Director U.S. Department of Justice
MEREDITH BURNS HEALY Trial Attorneys
WEI XIANG Trial Attorney
STIPULATION TO CONTINUE PRETRIAL MOTION DEADLINES
(SECOND REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou, Acting United States Attorney, and Mina Chang, Assistant United States Attorney, and Gustav W. Eyler, Director, and Meredith B. Healy and Wei Xiang, Trial Attorneys, U.S. Department of Justice, Consumer Protection Branch, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Nisha Brooks-Whittington, Assistant Federal Public Defender, counsel for Harold David Sobel., that the previously ordered deadline for filing of pretrial motions be vacated and that the parties herein shall have to and including April 25, 2022, within which to file the pretrial motions currently due April 11, 2022.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 9, 2022, to file any and all responsive pleadings, currently due April 25, 2022.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 16, 2022, to file any and all replies to dispositive motions, currently due May 2, 2022.
The Stipulation is entered into for the following reasons:
1. Counsel for the defendant needs additional time to investigate, research, and file pretrial motions.
2. The defendant is incarcerated and does not object to the continuance.
3. The parties agree to the continuance.
4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to research and file pretrial motions.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
This is the second stipulation to continue filed herein.
FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER
FINDINGS OF FACT, CONCLUSIONS OF LAW
Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:
1. Counsel for the defendant needs additional time to investigate, research, and file pretrial motions.
2. The defendant is incarcerated and does not object to the continuance.
3. The parties agree to the continuance.
4. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for defendant sufficient time within which to research and file pretrial motions.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
ORDER
IT IS THEREFORE ORDERED that the parties herein shall have to and including April 25, 2022, within which to file the Defendant's pretrial motions.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 9, 2022, to file any and all responsive pleadings.
IT IS FURTHER STIPULATED AND AGREED, by and between the parties, that they shall have to and including May 16, 2022, to file any and all replies to dispositive motions.