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Stipulated Motion to Extend Deadline to File Rule 33(a) Motion — No. 2:21-cr-00520 (Dkt. 271, D. Utah)

Summary

A two-page Stipulated Motion to Extend Deadline to File Rule 33(a) Motion, Document 271, filed 05/30/25 by Alexander E. Ramos of Langford | Ramos PLLC for Allison Marie Baver in United States v. Baver, Case No. 2:21-cr-00520, before District Judge Jill N. Parrish in the U.S. District Court for the District of Utah. Under Federal Rule of Criminal Procedure 45(b)(1)(B), and with the stipulation of government counsel Briggs Matheson, Baver asks the court to extend once again the June 6th, 2025 deadline for her Rule 33(a) Motion to Vacate Judgment and Grant a New Trial and to reset the status conference set on May 5th, 2025 for June 3rd, 2025. New defense counsel found that former counsel had never ordered the trial transcript, ordered it, and had not received it by filing; an extension of 45 days is requested.

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Cite this document

“Stipulated Motion to Extend Deadline to File Rule 33(a) Motion — No. 2:21-cr-00520 (Dkt. 271, D. Utah).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulated-motion-to-extend-deadline-to-file-rule-33-a-motion-no-2-21-67a8e40f01/, SHA-256 a953cdc11338d66919aa1d50052a8559c41632f6b5a0be8f61c5c5a437557200.

Full text

Case 2:21-cr-00520-JNP         Document 271         Filed 05/30/25      PageID.4125           Page 1 of 2




 Michael Langford (9682)
 Alexander E. Ramos (15234)
 LANGFORD | RAMOS PLLC
 43 E. 400 S.
 Salt Lake City, UT 84111
 Telephone: (801) 998-2002
 Email: alex@langfordramos.com

 Attorneys for Allison Marie Baver


                         IN THE UNITED STATES DISTRICT COURT
                                       DISTRICT OF UTAH

   UNITED STATES OF AMERICA,                            STIPULATED MOTION TO EXTEND
                                                          DEADLINE TO FILE RULE 33(a)
           Plaintiff,                                             MOTION

   v.


   ALLISON MARIE BAVER,                                        Case No. 2:21-cr-00520

                                                             District Judge Jill N. Parrish
        Defendant.


         Allison Marie Baver (“Ms. Baver”) through undersigned counsel, and pursuant to Federal

 Rule of Criminal Procedure 45(b)(1)(B) respectfully moves the Court to reschedule the currently

 scheduled status conference and extend the deadline to file a Rule 33(a) Motion to Vacate

 Judgment and Grant a New Trial. Counsel for the Government, Briggs Matheson, stipulates to

 this request.

                          Relevant Factual and Procedural Background

         Ms. Baver has until June 6th, 2025, to her File Rule 33(a) Motion to Vacate Judgment and

 Grant a New Trial. (ECF 265). On April 30th, 2025, defense counsel contacted chambers and the

 government requesting a status conference prior to the May 6th deadline to address some pre-

 filing issues. Alternatively, defense requested an extension of the deadline until after a status


                                                   1
Case 2:21-cr-00520-JNP        Document 271        Filed 05/30/25      PageID.4126        Page 2 of 2




 conference is held. Mr. Briggs indicated no objection to extending the deadline to accommodate

 the status conference request. On May 5th, 2025, a status conference was set for June 3rd, 2025.

 Defense counsel noticed that the transcript had not previously been requested by former counsel.

 Defense counsel ordered the transcript to ensure Ms. Baver’s Rule 33 motion was complete. It

 had anticipated to have it well in advance of today’s filing but has not. Defense counsel requests

 an additional extension to obtain this transcript, review it, and supplement Ms. Baver’s motion

 should it be deemed necessary.

                                            Conclusion

        For the reasons argued, Ms. Braver respectfully requests that the Court once again extend

 the June 6th, 2025 deadline to file a Rule 33(a) Motion to Vacate Judgment and Grant a New

 Trial and reset the currently scheduled status conference. An extension of 45 days is requested.

         Respectfully submitted this 30th day of May, 2025.



                                                      ____________________________________
                                                      Alexander E. Ramos
                                                      LANGFORD | RAMOS, PLLC.




                                                  2

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