Case 2:16-cr-00046-GMN-PAL Document 809 Filed 10/05/16 Page 1 of 3

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TODD M. LEVENTHAL, ESQ.

Leventhal and Associates, PLLC
Nevada Bar No. 8543
California Bar No. 223577
626 South Third Street
Las Vegas, Nevada 89101
(702) 472-8686
Attorney for Defendant
O.Scott Drexler
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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UNITED STATES OF AMERICA,

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Plaintiff,
CASE NO.: 2:16-CR-00146-GMN-PAL
vs.

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UNOPPOSED MOTION TO EXTEND TIME

O. SCOTT DREXLER,
Defendant.

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Comes Now, O.Scott Drexler, by and through his attorney of record , Todd M. Leventhal,
and hereby request the court to accept this UNOPPOSED MOTION to continue the pretrial
motions deadlines. The Courts case management order (ECF No. 321) set a deadline of October

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3, 2016 to file Rule 12 pretrial motions, a deadline of November 16, 2016 to file any responses,

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and a deadline of November 23, 2016, or seven days after the response, whichever is earlier, to

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file any replies. Mr. Drexler now moves the Court for a fourteen day extension of these

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deadlines. On October 5, 2016, undersigned counsel conferred with the governments counsel,

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who does not oppose this motion.

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Mr. Leventhal was recently appointed to this case on Friday, September 29, 2016. Mr. Leventhal

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spent the entire weekend trying to get a handle on the numerous filings in this case in order to

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assure that Mr. Drexler had filed or joined certain motions. Mr. Leventhal is set to review the

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case with Mr. Drexler on Friday October 7, 2016. Accordingly, undersigned counsel has not had

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an opportunity to discuss updates from the ongoing discovery review or the pretrial motions in

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Case 2:16-cr-00046-GMN-PAL Document 809 Filed 10/05/16 Page 2 of 3

this case with Mr. Drexler. Therefore, Mr. Drexler respectfully requests a two-week extension of

the Courts pretrial motions deadlines as follows:

Proposed deadline to file any Rule 12 pretrial motions: October 19, 2016

Proposed deadline to file any responses: November 16, 2016

Proposed deadline to file any replies: November 23, 2016, or seven days after the response,

whichever is earlier.

Respectfully submitted this 5th day of October, 2016.

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DATED this __5___day of ______October_____2016.

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____________/s/________________
TODD M. LEVENTHAL, ESQ.
Attorney for Mr. Drexler

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ORDER
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Good cause appearing, and because the government does not oppose the request,

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IT IS HEREBY ORDERED that Defendant O. SCOTT DREXLER Unopposed Motion to

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Continue the Pretrial Motions Deadline is GRANTED. The last day for Mr. Drexler to file any

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Rule 12 pretrial motions shall be October 19, 2016. The last day for the government to file any

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responses shall be November 16, 2016. The last day for Mr. Drexler to file any replies shall be

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November 23, 2016, or seven days after the governments response, whichever is earlier.

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Dated this ______ day of ______________ 2016

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HON. PEGGY A. LEEN
UNITED STATES MAGISTRATE JUDGE

Case 2:16-cr-00046-GMN-PAL Document 809 Filed 10/05/16 Page 3 of 3

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CERTIFICATE OF SERVICE
I hereby certify that on this 5th day of OCTOBER, 2016, a true and correct copy of
DEFENDANT O.Scott Drexler UNOPPOSED MOTION TO CONTINUE PRETRIAL
MOTIONS DEADLINES was served via the United States District Court CM/ECF system on all
parties or persons requiring notice
By /s/ Maribel Godinez, an Employee of LEVENTHAL AND ASSOCIATES