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United States v. Stoytchev

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
Dec 24, 2012
CASE NO.: 2:11-CR-00434-LDG-GWF (D. Nev. Dec. 24, 2012)

Opinion

CASE NO.: 2:11-CR-00434-LDG-GWF

12-24-2012

UNITED STATES OF AMERICA Plaintiff, v. EUGENI STOYTCHEV, et al. Defendant.

William H. Gamage, Esq. Nevada Bar No. 9024 GAMAGE & GAMAGE Attorney for Defendant Eugeni Stoytchev


William H. Gamage, Esq.
Nevada Bar No. 9024
GAMAGE & GAMAGE
Attorney for Defendant Eugeni Stoytchev

JOINDER IN MOTION TO CONTINUE

(Dkt. No. 319) (FIRST REQUEST)

COMES NOW, Defendant EUGENI STOYTCHEV (hereinafter "STOYTCHEV") by and through counsel of record William H. Gamage, Esq. of Gamage & Gamage and hereby joins in Co-Defendant MICHAEL VALES' Motion to Continue Trial (Dkt. No. 319) in the above titled matter. This Motion is made and based upon all papers and pleadings on file herein, the attached Memorandum of Points and Authorities, along with any oral argument deemed necessary by this Honorable Court.

GAMAGE & GAMAGE

______________________

William H. Gamage, Esq.

Nevada Bar No. 9024

5580 South Fort Apache Street, Suite 110

Las Vegas, Nevada 89148

PH: (702) 386-9529

FX: (702) 382-9529

Attorney for Defendant Eugeni Stoytchev

MEMORANDUM OF POINTS AND AUTHORITIES

Defendant STOYTCHEV hereby requests that his trial be continued; adopts the points and authorities submitted by Co-Defendant MICHAEL VALES in his Motion to Continue Trial; and offers the following additional information:

1. Counsel for STOYTCHEV was appointed to represent this Defendant on or about November 27, 2012 as prior CJA appointed counsel was deployed as an arm y reservist to Afghanistan. Consequently, prior counsel is not available to assist current counsel in getting up to speed on the nature of his prior investigation of the facts and circumstances surrounding the government's allegations against STOYTCHEV.

2. Between November 27, 2012 and today, counsel has had an opportunity to interview his client and to complete a cursory review of several discs containing discovery information. Additionally, counsel has reviewed discovery information made available in an online format. Thousands of documents have been produced by the Government in support of their case.

3. It does not appear that prior counsel retained any computer forensic expert or an investigator in support of the defense. Counsel likely will need these services regarding this matter.

4. This matter has been deemed 'complex' for purposes of discovery. Consequently, counsel for STOYTCHEV needs substantial additional time to appropriately prepare a defense in this matter in order to provide effective representation.

5. Defendant EUGENI STOYTCHEV is out of custody, has consented to the filing of this Joinder, and does not object to a continuance in this matter.

GAMAGE & GAMAGE

William H Gamage, Esq.

______________________

William H. Gamage, Esq.

Nevada Bar No. 9024

5580 South Fort Apache Street, Suite 110

Las Vegas, Nevada 89148

PH: (702) 386-9529

FX: (702) 382-9529

Attorney for Defendant Eugeni Stoytchev

CERTIFCATE OF SERVICE

I hereby certify that the above and foregoing JOINDER IN MOTION TO CONTINUE (Dkt. No. 319) (FIRST REQUEST) was served via the Court's electronic filing system on all counsel registered to this case.

William H. Gamage

EMPLOYEE OF GAMAGE & GAMAGE

ORDER

IT IS SO ORDERED.

_________________

Lloyd D. George

Sr. U.S. District Judge


Summaries of

United States v. Stoytchev

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
Dec 24, 2012
CASE NO.: 2:11-CR-00434-LDG-GWF (D. Nev. Dec. 24, 2012)
Case details for

United States v. Stoytchev

Case Details

Full title:UNITED STATES OF AMERICA Plaintiff, v. EUGENI STOYTCHEV, et al. Defendant.

Court:UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

Date published: Dec 24, 2012

Citations

CASE NO.: 2:11-CR-00434-LDG-GWF (D. Nev. Dec. 24, 2012)