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

1 CHRIS T. RASMUSSEN, ESQ. Nevada Bar 7149 2 RASMUSSEN & KANG rd 3 330 South 3 Street, Suite 1010 Las Vegas, Nevada 89101 4 (702) 464-6007 Attorney for Ginger Gutierrez 5 6 7 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA *** ) ) Plaintiff, ) ) v. ) ) GINGER GUTIERREZ, ) ) Defendant. ) ________________________________)

9 UNITED STATES OF AMERICA, 10 11 12 13 14 15 16

2:09-CR-00132-JAD-GWF MOTION TO REMOVE PRETRIAL SUPERVISION

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

17 RASMUSSEN, ESQ., comes before the Court with a Motion to Remove Pretrial 18 Supervision 19 20 21 22 23 24 25 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). MEMORANDUM OF POINTS AND AUTHORITIES Pretrial Supervision Is Not Necessary To Ensure Gutierrezs Appearance Or Safety Of The Community

26 It has been four and half years since she was indicted and there has not been a single 27 incident during her pretrial supervision. The trial is currently set for April 29, 2014. 28

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

1 However, this trial date likely to be continued as the number one defendant John 2 3 4 5 the trial at least until the fall of 2014, more than five years since Gutierrez indictment. 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

6 The government has indicated that they will defer to pretrial services regarding the 7 issue of pretrial supervision. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _______________________ CHRIS THOMAS RASMUSSEN Attorney for Ginger Gutierrez DATED this 27th day of October, 2013. /s/ Chris Thomas Rasmussen

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