Stipulation to Extend Discovery Deadlines — United States v. Meelad Dezfooli (Dkt. 25)

Summary

A Stipulation to Extend Discovery Deadlines, Case 2:22-cr-00142, Document 25, filed 07/22/22, United States of America v. Meelad Dezfooli, District of Nevada. It is entered between Jason M. Frierson, Eric C. Schmale and D. Zachary Adams for the United States and David Chesnoff and Richard Schonfeld, attorneys for Defendant Meelad Dezfooli. It states that on July 18, 2022, counsel David Chesnoff, Esq. filed a motion to withdraw (ECF No. 19) that remains pending. The parties ask that the deadlines for a discovery conference and the government disclosure statement be continued 21 days, to August 8, 2022, and August 15, 2022. The signature lines read /s/ David Z. Chesnoff and /s/ Eric C. Schmale, dated the 20th day of July, 2022, and a [PROPOSED] ORDER follows.

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“Stipulation to Extend Discovery Deadlines — United States v. Meelad Dezfooli (Dkt. 25).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-plaintiff-v-meelad-dezfooli-dkt-25-b7b53b730b/, SHA-256 015f9dd1abffe557c33ff36ba9ec3bc7595d82efb95dd0e36dff5ac1176696be.

Full text

Case 2:22-cr-00142-RFB-DJA Document 25 Filed 07/22/22 Page 1 of 4

1 JASON M. FRIERSON
United States Attorney
2 Nevada Bar No. 7709
ERIC C. SCHMALE
3 Assistant United States Attorney
501 Las Vegas Blvd. South, Ste. 1100
4 Las Vegas, Nevada 89101
Phone: 702-388-6336
5 Email: eric.schmale@usdoj.gov

6 DEBORAH CONNOR
Chief, Money Laundering and Asset Recovery Section
7 Criminal Division, U.S. Department of Justice
D. ZACHARY ADAMS
8 Trial Attorney
1400 New York Ave NW
9 Washington, D.C. 20005
Telephone: (202) 514-1263
10 Email: david.zachary.adams@usdoj.gov

11 Attorneys for the United States

12
UNITED STATES DISTRICT COURT
13 DISTRICT OF NEVADA

14 UNITED STATES OF AMERICA, Case No.: 2:22-CR-142-RFB-DJA

15 Plaintiff,
STIPULATION TO EXTEND
16 DISCOVERY DEADLINES
v.

17 MEELAD DEZFOOLI,

18 Defendant.

21 It is hereby stipulated and agreed, by and between Jason M. Frierson, United States

22 Attorney, and Eric C. Schmale, Assistant United States Attorney, and D. Zachary Adams,

23 Trial Attorney, Money Laundering and Asset Recovery Section; and David Chesnoff and

24 Richard Schonfeld, Esq., attorneys for Defendant Meelad Dezfooli, that the Court to extend
Case 2:22-cr-00142-RFB-DJA Document 25 Filed 07/22/22 Page 2 of 4

1 the deadlines for meeting and conferring regarding discovery, and the deadline for the

2 government disclosure statement.

3 This Stipulation is entered into based on the following circumstances and reasons:

4 1. The initial appearance and arraignment for defendant Meelad Dezfooli was held

5 on July 11, 2022. Local Rule 16-1(b)(2) provides that within seven days of

6 arraignment, the parties must meet and confer regarding discovery. The local rule

7 further provides that within seven days of this conference, the government must

8 file its disclosure statement.

9 2. At the July 11, 2022, proceeding, David Chesnoff, Esq. and Richard A Schonfeld,

10 Esq., entered a special appearance on behalf of the defendant for purposes of the

11 initial appearance and detention hearing. ECF No. 14. The Honorable Magistrate

12 Judge Brenda Weksler ordered Defendant to provide a status update regarding his

13 legal representation no later than July 18, 2022. ECF No. 6.

14 3. On July 18, 2022, counsel for the defendant David Chesnoff, Esq., filed a motion

15 to withdraw from the case and recommended that the case be referred to the

16 Federal Public Defender. ECF No. 19. That motion remains pending.

17 4. Also on July 18, 2022, the government called Mr. Chesnoff to confer regarding

18 discovery. In this call, the parties agreed that it would be appropriate for the

19 discovery conference to proceed after the Court has ruled on defense counsel’s

20 motion to withdraw and any new counsel of record has appeared on behalf of the

21 defendant.

22 5. Accordingly, the parties request that the deadlines for a discovery conference and

23 the government filing of a government disclosure statement be continued 21 days

24 from the present deadlines under the Local Rules, and that the parties shall have

2
Case 2:22-cr-00142-RFB-DJA Document 25 Filed 07/22/22 Page 3 of 4

1 until August 8, 2022, to confer regarding discovery, and the government shall

2 have until August 15, 2022, to file its disclosure statement.

4
DATED this 20th day of July, 2022.
5

6 JASON M. FRIERSON CHESNOFF & SCHONFELD, PC
United States Attorney
7 /s/ David Z. Chesnoff
/s/ Eric C. Schmale DAVID Z. CHESNOFF
8 ERIC C. SCHMALE RICHARD A. SCHONFELD
Assistant United States Attorney
9 D. ZACHARY ADAMS
Trial Attorney
10

3
Case 2:22-cr-00142-RFB-DJA Document 25 Filed 07/22/22 Page 4 of 4

1 UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
2
UNITED STATES OF AMERICA,
3
Plaintiff, Case No.: 2:22-CR-142-RFB-DJA
4
vs.
___________ ORDER
[PROPOSED]
5
MEELAD DEZFOOLI,
6
Defendant.
7

8 Based on the pending Stipulation of counsel, and good cause appearing therefore, the

9 Court ORDERS that counsel for the parties shall hold a discovery conference no later than

10 August 8, 2022
______________________, and that the government shall file its disclosure statement no

11 August 15, 2022
later than _______________________.

12 22nd day of July 2022,
Dated this _____

14 By: _________________________________
RICHARD F. BOULWARE II
15 UNITED STATES. DISTRICT JUDGE

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