gutierrez ginger supervision 10-27-2013 show_temp.pdf

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CHRIS T. RASMUSSEN, ESQ. Nevada Bar 7149 RASMUSSEN & KANG 330 South 3 rd 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 REMOVE PRETRIAL ) SUPERVISION GINGER GUTIERREZ, ) ) Defendant. ) ________________________________) Defendant, GINGER GUTIERREZ, by and through her attorney, CHRIS T. RASMUSSEN, ESQ., comes before the Court with a Motion to Remove Pretrial Supervision MEMORANDUM OF POINTS AND AUTHORITIES Pretrial Supervision Is Not Necessary To Ensure Gutierrez’s Appearance Or Safety Of The Community Gutierrez was indicted May 27, 2009. (DK 7). She was originally placed on a Personal Recognizance Bond at her initial arraignment and detention hearing. (DK 41). It has been four and half years since she was indicted and there has not been a sing le incident during her pretrial supervision. The trial is currently set for April 29, 2014. Case 2:09-cr-00132-JAD-GWF Document 203 Filed 10/27/13 Page 1 of 3

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Page 1: GUTIERREZ GINGER SUPERVISION  10-27-2013 show_temp.pdf

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CHRIS T. RASMUSSEN, ESQ.Nevada Bar 7149RASMUSSEN & KANG330 South 3rd Street, Suite 1010Las Vegas, Nevada 89101(702) 464-6007Attorney for Ginger Gutierrez

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA* * *

UNITED STATES OF AMERICA, ))

Plaintiff, ) 2:09-CR-00132-JAD-GWF)

v. ) MOTION TO REMOVE PRETRIAL ) SUPERVISION

GINGER GUTIERREZ, ))

Defendant. )________________________________)

Defendant, GINGER GUTIERREZ, by and through her attorney, CHRIS T.

RASMUSSEN, ESQ., comes before the Court with a Motion to Remove Pretrial

Supervision

MEMORANDUM OF POINTS AND AUTHORITIES

Pretrial Supervision Is Not Necessary To Ensure Gutierrez’s Appearance OrSafety Of The Community

Gutierrez was indicted May 27, 2009. (DK 7). She was originally placed on a

Personal Recognizance Bond at her initial arraignment and detention hearing. (DK 41).

It has been four and half years since she was indicted and there has not been a single

incident during her pretrial supervision. The trial is currently set for April 29, 2014.

Case 2:09-cr-00132-JAD-GWF Document 203 Filed 10/27/13 Page 1 of 3

Page 2: GUTIERREZ GINGER SUPERVISION  10-27-2013 show_temp.pdf

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However, this trial date likely to be continued as the number one defendant John

Edwards finally exhausting his appellate rights in the United Kingdom. It is anticipated

that Edwards will be extradited to our District by the January. This will likely continue

the trial at least until the fall of 2014, more than five years since Gutierrez indictment.

The government has indicated that they will defer to pretrial services regarding the

issue of pretrial supervision.

DATED this 27th day of October, 2013.

/s/ Chris Thomas Rasmussen

_______________________CHRIS THOMAS RASMUSSENAttorney for Ginger Gutierrez

Case 2:09-cr-00132-JAD-GWF Document 203 Filed 10/27/13 Page 2 of 3

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Case 2:09-cr-00132-JAD-GWF Document 203 Filed 10/27/13 Page 3 of 3