Opinion
2:21-cr-00235-APG-EJY
08-24-2022
UNITED STATES OF AMERICA, Plaintiff, v. HAROLD DAVID SOBEL, Defendant.
Jacob B. Lee NV Bar No. 012428 Ashlee B. Hesman NV Bar No. 012740 STRUCK LOVE BOJANOWSKI & ACEDO, PLC Gina G. Winspear Nevada Bar No. 005552 DENNETT WINSPEAR, LLP Attorneys for Non-Party CoreCivic, Inc. JASON FRIERSON United States Attorney MINA CHANG Assistant United States Attorney GUSTAV W. EYLER Director, U.S. Department of Justice MEREDITH BURNS HEALY Trial Attorney WEI XIANG Trial Attorney JACQUELINE TIRINNANZI, ESQ. Counsel for Harold David Sobel
Jacob B. Lee
NV Bar No. 012428
Ashlee B. Hesman
NV Bar No. 012740
STRUCK LOVE BOJANOWSKI & ACEDO, PLC
Gina G. Winspear
Nevada Bar No. 005552
DENNETT WINSPEAR, LLP
Attorneys for Non-Party CoreCivic, Inc.
JASON FRIERSON
United States Attorney
MINA CHANG
Assistant United States Attorney
GUSTAV W. EYLER
Director, U.S. Department of Justice
MEREDITH BURNS HEALY
Trial Attorney
WEI XIANG
Trial Attorney
JACQUELINE TIRINNANZI, ESQ.
Counsel for Harold David Sobel
STIPULATION TO EXTEND TIME FOR CORECIVIC'S RESPONSE TO DEFENDANT'S MOTION FOR RELEASE AND TO REPLY REGARDING THE MOTION AND PROPOSED ORDER
(SECOND REQUEST)
HONORABLE ANDREW P. GORDON, UNITED STATES DISTRICT JUDGE
IT IS HEREBY STIPULATED AND AGREED, by and between Jason Frierson, United States Attorney for the District of Nevada, 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; Jacqueline Tirinnanzi and Kathleen Bliss, counsel for Harold David Sobel (“Defendant”); and Jacob B. Lee, counsel for Non-Party CoreCivic, Inc. (“CoreCivic”), that the parties request this Court to extend the deadline for CoreCivic to file its Response to Defendant's Motion for Release Pending Sentencing and Supplement (Dkt. 55, 58) by one day to August 23, 2022.
On July 22, 2022, Defendant filed a Motion for Release Pending Sentencingl (Dkt. 55) and on July 29, 2022, filed a Supplement to the Motion (Dkt. 58). The general basis of the Motion concerned Defendant's medical care at CoreCivic's Nevada Southern Detention Center (“NSDC”), where he is currently detained. The government filed its Response to Defendant's Motion on August 5, 2022. (Dkt. 61.) That same day, CoreCivic filed a Notice Regarding Defendant's Motion for Release Pending Sentencing and Supplement. (Dkt. 64.) On August 8, 2022, this Court ordered CoreCivic to file a Response as to Defendant's medical care by August 22, 2022. (Dkt. 65.)
Defendant and the government thereafter stipulated and requested that the Court allow Defendant to file his Reply to the government's and CoreCivic's responses within three days of the filing of CoreCivic's Response and for the government to file a Reply only as to CoreCivic's Response by the same date-i.e., by August 25, 2022. (Dkt. 66.) The Court granted the stipulation on August 15, 2022. (Dkt. 67.)
Due to unforeseen logistical complications, CoreCivic has been unable to finalize the Declaration of Jay Peterson, APRN, who is one of Defendant's medical providers at NSDC. Extending the deadline for CoreCivic's Response by one day to August 23, 2022 will allow CoreCivic to finalize APRN Peterson's Declaration and obtain his signature on it. In light of this extension, the parties further stipulate and request that the Court extend the government's and Defendant's deadline to file their Replies to August 26, 2022.
Denial of this request would deny CoreCivic the ability to provide the Court with a complete picture of the care Defendant is receiving at NSDC and would deny counsel for Defendant the opportunity to prepare a complete Reply to the additional information to be provided by CoreCivic as it relates to this original Motion and Supplement. This stipulation and request for extension of these deadlines is mindful of the exercise of due diligence, in the interests of justice, and not for any purposes of delay.
IT IS SO ORDERED.