Stipulation and [Proposed] Order to Extend Deadline to File Motion to Suppress Statements for Impeachment Purposes [2nd Request] — United States v. Ribal Hajj-Hussein, No. 2:22-cr-00169-JCM-EJY (Dkt. 33, D. Nev.)

Summary

Federal prosecutors and the defense agreed on April 4, 2024 to extend Ribal Hajj-Hussein's deadline to file a motion to suppress statements for impeachment purposes to April 15, 2024 in United States v. Hajj-Hussein, No. 2:22-cr-00169-JCM-EJY (D. Nev.). The stipulation, signed by Assistant U.S. Attorney Mina Chang for U.S. Attorney Jason M. Frierson and by defense attorney Richard A. Schonfeld, says the parties were in active negotiations to resolve the case, the government does not object and the delay is not sought in bad faith. It is the second request to extend this briefing. The stipulation ends with an order page, dated April 5, 2024, allowing the motion to be filed through April 15, 2024.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

            Case 2:22-cr-00169-JCM-EJY Document 32
                                                33 Filed 04/05/24 Page 1 of 3



 1   RICHARD A. SCHONFELD, ESQ.
     Nevada Bar No. 6815
 2   CHESNOFF & SCHONFELD
 3   520 South Fourth Street
     Las Vegas, Nevada 89101
 4   Tel.: (702) 384-5563
     Fax: (702) 598-1425
 5   rschonfeld@cslawoffice.net
     Attorney for Defendant, Ribal Hajj-Hussein
 6

 7                       UNITED STATES DISTRICT COURT
                               DISTRICT OF NEVADA
 8                                    ****
     UNITED STATES OF AMERICA         )
 9                                    ) CASE NO: 2:22-cr-00169-JCM-EJY
                    Plaintiff,        )
10                                    ) STIPULATION AND [PROPOSED] ORDER
11   v.                               ) TO EXTEND DEADLINE TO FILE MOTION
                                      ) TO SUPPRESS STATEMENTS FOR
12   RIBAL HAJJ-HUSSEIN,              ) FOR IMPEACHMENT PURPOSES
                                      ) [2nd REQUEST]
13                                    )
                    Defendant.        )
14                                    )
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            IT IS HEREBY STIPULATED and AGREED by and between Jason M. Frierson, United
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     States Attorney, Mina Chang, Assistant United States Attorney, and Richard A. Schonfeld, Esq.,
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     attorney for Defendant, Ribal Hajj-Hussein that Defendant’s deadline to file a Motion to Suppress
18

19   his Statements for Impeachment Purposes shall be extended to April 15, 2024.

20           This Stipulation is entered into for the following reasons:

21          1.      The parties were in active negotiations and were attempting to resolve the case;
22          2.      The United States Attorney Mina Chang does not object to the requested extension;
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            3.      The additional time requested herein is not sought for purposes of bad faith delay;
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           Case 2:22-cr-00169-JCM-EJY Document 32
                                               33 Filed 04/05/24 Page 2 of 3



 1          4.     This is the second request to extend the briefing on Defendant’s Motion to Suppress
 2   his Statements for Impeachment Purposes.
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     DATED this 4th day of April, 2024.                 DATED this 4th day of April, 2024.
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     UNITED STATES ATTORNEY                             CHESNOFF & SCHONFELD
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 6     /s/ Mina Chang                                   /s/ Richard A. Schonfeld
 7   JASON M. FRIERSON, USA                             RICHARD A. SCHONFELD, ESQ.
     MINA CHANG, AUSA                                   Nevada Bar No. 6815
 8   501 Las Vegas Blvd., Suite 1100                    520 South Fourth Street
     Las Vegas, Nevada 89101                            Las Vegas, Nevada 89101
 9   Attorney for Plaintiff                             Attorney for Defendant, Ribal Hajj-Hussein
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           Case 2:22-cr-00169-JCM-EJY Document 33
                                               32 Filed 04/05/24 Page 3 of 3



 1                                                ORDER
 2          Based on the stipulation of the parties, and with good cause appearing, IT IS THEREFORE
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     ORDERED that Defendant shall have to and including April 15, 2024, within which to file his
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     Motion to Suppress his Statements for Impeachment Purposes.
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            IT IS SO ORDERED.
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 7                 April 5, day
            DATED this      2024.
                                of                                 , 2024.

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11                                                      UNITED STATES DISTRICT JUDGE

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     Submitted by:
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       /s/ Richard A. Schonfeld
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     RICHARD A. SCHONFELD, ESQ.
15   Nevada Bar No. 6815
     CHESNOFF & SCHONFELD
16   520 South Fourth Street
     Las Vegas, Nevada 89101
17   Tel.: (702) 384-5563
     Fax: (702) 598-1425
18
     rschonfeld@cslawoffice.net
19   Attorney for Defendant, Ribal Hajj-Hussein

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