Opinion
CASE NO.: 2:11-CR-00434-LDG-GWF
12-24-2012
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