gutierrez ginger supervision 10-27-2013 show_temp.pdf
DESCRIPTION
Gutierrez Edwards InfoTRANSCRIPT
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 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
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
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
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
Case 2:09-cr-00132-JAD-GWF Document 203 Filed 10/27/13 Page 3 of 3