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Stipulation to Continue Preliminary Hearing (First Request) — United States v. Holmes (D. Nev., Dkt. 24)

Summary

A Stipulation to Continue Preliminary Hearing (First Request) with an order, filed 11/18/20 as Document 24 in Case 2:21-cr-00212-APG-EJY, in the District of Nevada, captioned United States of America v. Joseph Holmes, Case No. 2:20-mj-00902-DJA. United States Attorney Nicholas A. Trutanich and Assistant United States Attorney Jim W. Fang, with Federal Public Defender Rene L. Valladares and Assistant Federal Public Defender Kathryn C. Newman for Holmes, ask that the November 23, 2020 preliminary hearing be vacated and continued to a date no sooner than sixty (60) days. The reasons given are that the parties have entered negotiations, the government is producing discovery, and Holmes is not incarcerated and does not object. An order with a signature block for U.S. Magistrate Judge Daniel J. Albregts vacates that hearing.

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“Stipulation to Continue Preliminary Hearing (First Request) — United States v. Holmes (D. Nev., Dkt. 24).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-nev-no-2-21-cr-00212-dkt-24-58375a5a19/, SHA-256 572ed53cca2d1c14b815153fbaca19f60842f2d96db4fb311761204ed665b4f9.

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Case 2:21-cr-00212-APG-EJY Document 24

RENE L. VALLADARES
Federal Public Defender
Nevada State Bar No. 11479
KATHRYN C. NEWMAN
Assistant Federal Public Defender
Nevada State Bar No. 13733
411 E. Bonneville, Ste. 250
Las Vegas, Nevada 89101
(702) 388-6577/Phone

(702) 388-626 1/Fax
Kathryn_Newman@fd.org

Attorney for Joseph Holmes

Filed 11/18/20 Page1of3

Case 2:20-mj-00902-DJA Document 23 Filed 11/13/20 Page 1 of 3

— thre ED —____- SERVED ON
ENTER COUNSEL/PARTIES OF RECORD

NOV 16 2020
“Cl T
CLERK US DISTRICT COUR
, DISTRICT OF NEVADA ory

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, Case, No. 2:20-mj-00902-DJA
Plaintiff, STIPULATION TO CONTINUE
PRELIMINARY HEARING
v. (First Request)
JOSEPH HOLMES,
Defendant.

matter.

IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A.
Trutanich, United States Attorney, and Jim W. Fang, Assistant United States Attorney, counsel
for the United States of America, and Rene L. Valladares, Federal Public Defender, and Kathryn
C. Newman, Assistant Federal Public Defender, counsel for Joseph Holmes, that the
Preliminary Hearing currently scheduled on November 23, 2020, be vacated and continued to
a date and time convenient to the Court, but no sooner than sixty (60) days.

This Stipulation is entered into for the following reasons:

1. Parties have entered negotiations and need the additional time to resolve this
SN A Ff WY NY §—§ Oo OO fF NHN DB A BP W NY KH BS

Case 2:21-cr-00212-APG-EJY Document 24 _ Filed 11/18/20 Page2of3
Case 2:20-mj-00902-DJA Document 23 Filed 11/13/20 Page 2 of 3

2, The government is in the process of producing discovery, which will allow Mr.
Holmes to evaluate the case against him and, if necessary, prepare for the preliminary hearing.

3. Defendant is not incarcerated and does not object to a continuance.

4, Additionally, denial of this request for continuance could result in a
miscarriage of justice.

This is the first request for continuance filed herein.

DATED this 13th day of November, 2020.

RENE L. VALLADARES NICHOLAS A. TRUTANICH
Federal Public Defender United States Attorney
/s/ Kathryn C. Newman /s/ Jim W. Fang
By By
KATHRYN C. NEWMAN JIM W. FANG
Assistant Federal Public Defender Assistant United States Attorney
Case 2:21-cr-00212-APG-EJY Document 24 _ Filed 11/18/20 Page3of3
Case 2:20-mj-00902-DJA Document 23 Filed 11/13/20 Page 3 of 3

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, Case No. 2:20-mj-00902-DJA
Plaintiff, ORDER

JOSEPH HOLMES,

Defendant.

Based on the Stipulation of counsel and good cause appearing,

IT IS THEREFORE ORDERED that the Preliminary Hearing currently scheduled on
November 23, 2020 at the hour of 4:00 p.m., be vacated and continued to
Tanuary Hy 20él at the hour of 4-00 fm.

| th
DATED this !(0 ~ day of November, 2020.

UNITED STATES MAGISTRATE JUDGE

DANIEL J. ALBREGTS
U.S. MAGISTRATE JUDGE

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