Order Approving Stipulation on Briefing Schedule for Post-Trial Motions — U.S. v. Meelad Dezfooli, Dkt. 305

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An Order Approving Stipulation Regarding Briefing Schedule for Post-Trial Motions (Third Request), Case 2:22-cr-00142, Document 305, filed 12/06/24, District of Nevada. The stipulation states that on October 2, 2024, the Court appointed new counsel for post-trial motions and sentencing, and that the trial transcripts would not be completed until December 16, 2024. Dezfooli requests a sixty (60) day extension, and counsel for the United States do not object to a 60-day continuance. The parties stipulate that motions under Rules 29 and 33 of the Federal Rules of Criminal Procedure are due on or before February 13, 2025, responses on or before February 27, 2025, and the reply brief on or before March 10, 2025. The order line is dated December 6, 2024.

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Case 2:22-cr-00142-CDS-DJA Document 305 Filed 12/06/24 Page1of3

LUCAS J. GAFFNEY, ESQ.

Nevada Bar No. 12373
GAFFNEYLAW

9900 Covington Cross Drive, Suite 290
Las Vegas, Nevada 89144

Telephone: (702) 742-2055

Facsumile: (702) 920-8838
lucas@gaffneylawlv.com

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

UNITED STATES OF AMERICA, CASE NO: 2:22-cr-00142-CDS-DJA
Plaintiff Order Approving STIPULATION
) REGARDING BRIEFING SCHEDULE
vs. FOR POST-TRIAL MOTIONS
MEELAD DEZFOOLI (Third Request)
Defendant [ECF No. 303]

IT IS HEREBY STIPULATED AND AGREED by and between Jason M. Frierson,

United States Attorney; and David Zachruy Adams and Taylor G Stout, Trial Attorneys,
Criminal Division, U.S. Depruiment of Justice, Money Laundering and Asset Recovely
Section; and Assistant United States Attorney, Daniel R Schiess, counsel for the United

States of America; and Defendant MEELAD DEZFOOLI by and through his attorney, Lucas
J. Gaffney, Esq., as follows:

lL Thejmy retmned its verdicts in the present case on September 4, 2024, as to the chru-ges
contained m the Superseding Indictment, and on September 5, 2024, as to the
Forfeiture allegations contained therein. The post-trial motions MEELAD DEZFOOLI
intended to file nre due on December 5, 2024. See ECF No. 256,259,277,278.
2. On October 2, 2024, this Court appointed new counsel to represent MEELAD

DEZFOOLI for post-trial motions and sentencing. Given his relatively recent
appointment, current counsel requires an extension of time to familiarize himself with

the testimony and evidence presented at trial before filing the post-trial motions.

. The trial took eight (8) days and involved the testimony of twenty-five (25) witnesses.

There is also a significant amount of related material in the form of trial exhibits which
must be reviewed in order to draft effective post-trial motions pursuant to Rules 29 and
33 of the Federal Rules of Criminal Procedure. All of which necessitate an extension of
the due dates for said motions and a modification of the normal briefing schedule for

oppositions and replies.

. On October 4, 2024, current counsel requested MEELAD DEZFOOLI’S trial transcripts

for the purpose of identifying which issues should be raised in post-trial motion(s). Court
Reporter/Recorder Samantha McNett initially indicated it will take up to thirty (30) days

to prepare the transcripts.

. On October 10, 2024, MEELAD DEFOOLI filed an unopposed motion to extend the

briefing schedule for his post-trial motions. ECF No. 277. On October 15, 2024, this
Court granted the motion, and set a due date of December 6, 2024, for the post-trial

motions.

. On November 14, 2024, Samantha McNett filed a Motion for Extension of Time to File

Transcript in MEELAD DEZFOOLI’S Ninth Circuit Court of Appeals case number 24-
5752. See Dkt Entry 7.1. The motion indicated the trial transcripts would not

be completed until December 16, 2024.!

! On November 21, 2024, the Ninth Circuit dismissed the appeal, however, Ms. McNett still needs
until December 16th to finish all the requested transcripts.
Case 2:22-cr-00142-CDS-DJA Document 305 Filed 12/06/24 Page3of3

7. Given the delay in completing the trial transcripts MEELAD DEZFOOLI
respectfully requests a sixty (60) day extension to file his post-trial motions.

8. Counsel forthe United States of America—David Zachery Adams, TaylorG. Stout, and
Daniel R. Schiess—do not object to a 60-day continuance of the

post-trial motion briefing schedule.

9. The parties hereby stipulate and agree that MEELAD DEZFOOLI’S motions
pursuant to Rules 29 and 33 of the Federal Rules of Criminal Procedure shall be due
on or before February 13, 2025, and responses or oppositions to said motions shall

be filed on or before February 27, 2025. MEELAD DEZFOOLDS reply brief shall

be filed on or before March 10, 2025.2
IT IS SO STIPULATED this 4th day of December 2024.

Respectfully submitted, JASON FRIERSON

United States Att
/s/ Lucas Gaffney nited states Attorney

LUCAS J. GAFFNEY, ESQ. /s/ Dan Schiess
Attorney for Meelad Dezfooli DANIEL R. SCHIESS
Attorney for the United States of America

/s/ Taylor Stout

Attorney for the United States of America

/s/ David Adams
David Zachary Adams
Attorney for the United States of America

IT ISSO ORDERED.

CRI A D-SILVA
[ED STATES DISTRICT JUDGE

Dated: December 6, 2024

* The parties are mindful the proposed briefing schedule extends beyond the current sentencing
date of February13, 2025. The parties intend to make a concerted effort to complete the post-

trial motion briefing prior to the suggested deadlines in hopes of maintaining the current
sentencing date.


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