Post by imSINGLEruRICH on Oct 16, 2014 7:59:17 GMT -5
dyemenz
Previously posted Ginger Gutierrez's attorney had a prior scheduled trial in conflict with his client's federal trial in January 2015
CHRIS T. RASMUSSEN, ESQ.
Nevada Bar 7149
RASMUSSEN & KANG
330 South 3rd Street, Suite 1010
Las Vegas, Nevada 89101
(702) 464-6007
Attorney for Ginger Gutierrez
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
* * *
UNITED STATES OF AMERICA, )
)
Plaintiff, ) 2:09-CR-00132-JAD-GWF
)
v. ) MOTION TO CONTINUE
) CALENDAR CALL, TRIAL, AND
GINGER GUTIERREZ, ) MOTIONS DEADLINES WITH
) DECLARATION OF COUNSEL
Defendant. )
________________________________)
Defendant, GINGER GUTIERREZ, by and through her attorney, CHRIS T.
RASMUSSEN, ESQ., comes before the Court with a Motion to Continue Calendar Call,
Trial, and Motions Deadlines.
MEMORANDUM OF POINTS AND AUTHORITIES
Calendar Call is set for December 31, 2014 and trial January 6, 2015. Counsel
for Ginger Gutierrez has a calendar call in United States v. Benzer (2:13-cr-00018-JCMGWF)
on February 4, 2015. This trial will certainly go into the middle of February.
Additionally, Counsel received 65 disks with over 400 thousand pages of discovery,
approximately three weeks ago. This discovery focuses mainly on the GBDX portion of
the indictment. The government at the last hearing had indicated that they would file a
Case 2:09-cr-00132-JAD-GWF Document 272 Filed 10/14/14 Page 1 of 5
motion to sever the GBDX defendant. However, no such motion has been filed and all
counsel have been forced to prepare for this GBDX portion of the indictment. This
portion alone contains over 500 thousand pages and foreign language recordings that
have yet to be translated.
The lead defendant John Edwards was recently sent to California to be
evaluated for mental health issues. His return to this District would not occur until at
least March 2015. A mid-summer or fall 2015 seems like a more practical trial date.
DATED this 14th day of October, 2014.
/s/ Chris Thomas Rasmussen
_______________________
CHRIS THOMAS RASMUSSEN
Attorney for Ginger Gutierrez
DECLARATION OF CHRIS T. RASMUSSEN
I declare the following is true and correct under the penalty of perjury:
1. I am the counsel of record for Ginger Gutierrez in the instant case and counsel of
record for Edith Gillespie in the Benzer case.
2. The calendar call in the Benzer case is set for calendar call on February 4, 2015.
The trial in the instant case is set for January 6, 2015. The Government has
indicated that it will take them 6-8 weeks to present their case in chief.
4. The Government recently disclosed 400 thousand pages of discovery. Counsel
for Gutierrez has yet to review the previously disclosed million plus pages of
discovery.
3. The client has no objection to a continuance of the trial.
Dated this 14th of October, 2014.
/s/ Chris T. Rasmussen
________________________________
Chris T. Rasmussen, Esq.
Attorney for Gutierrez
Previously posted Ginger Gutierrez's attorney had a prior scheduled trial in conflict with his client's federal trial in January 2015
CHRIS T. RASMUSSEN, ESQ.
Nevada Bar 7149
RASMUSSEN & KANG
330 South 3rd Street, Suite 1010
Las Vegas, Nevada 89101
(702) 464-6007
Attorney for Ginger Gutierrez
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
* * *
UNITED STATES OF AMERICA, )
)
Plaintiff, ) 2:09-CR-00132-JAD-GWF
)
v. ) MOTION TO CONTINUE
) CALENDAR CALL, TRIAL, AND
GINGER GUTIERREZ, ) MOTIONS DEADLINES WITH
) DECLARATION OF COUNSEL
Defendant. )
________________________________)
Defendant, GINGER GUTIERREZ, by and through her attorney, CHRIS T.
RASMUSSEN, ESQ., comes before the Court with a Motion to Continue Calendar Call,
Trial, and Motions Deadlines.
MEMORANDUM OF POINTS AND AUTHORITIES
Calendar Call is set for December 31, 2014 and trial January 6, 2015. Counsel
for Ginger Gutierrez has a calendar call in United States v. Benzer (2:13-cr-00018-JCMGWF)
on February 4, 2015. This trial will certainly go into the middle of February.
Additionally, Counsel received 65 disks with over 400 thousand pages of discovery,
approximately three weeks ago. This discovery focuses mainly on the GBDX portion of
the indictment. The government at the last hearing had indicated that they would file a
Case 2:09-cr-00132-JAD-GWF Document 272 Filed 10/14/14 Page 1 of 5
motion to sever the GBDX defendant. However, no such motion has been filed and all
counsel have been forced to prepare for this GBDX portion of the indictment. This
portion alone contains over 500 thousand pages and foreign language recordings that
have yet to be translated.
The lead defendant John Edwards was recently sent to California to be
evaluated for mental health issues. His return to this District would not occur until at
least March 2015. A mid-summer or fall 2015 seems like a more practical trial date.
DATED this 14th day of October, 2014.
/s/ Chris Thomas Rasmussen
_______________________
CHRIS THOMAS RASMUSSEN
Attorney for Ginger Gutierrez
DECLARATION OF CHRIS T. RASMUSSEN
I declare the following is true and correct under the penalty of perjury:
1. I am the counsel of record for Ginger Gutierrez in the instant case and counsel of
record for Edith Gillespie in the Benzer case.
2. The calendar call in the Benzer case is set for calendar call on February 4, 2015.
The trial in the instant case is set for January 6, 2015. The Government has
indicated that it will take them 6-8 weeks to present their case in chief.
4. The Government recently disclosed 400 thousand pages of discovery. Counsel
for Gutierrez has yet to review the previously disclosed million plus pages of
discovery.
3. The client has no objection to a continuance of the trial.
Dated this 14th of October, 2014.
/s/ Chris T. Rasmussen
________________________________
Chris T. Rasmussen, Esq.
Attorney for Gutierrez