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United States v. Alvidrez

United States District Court, D. Nevada

June 7, 2017

UNITED STATES OF AMERICA, Plaintiff,
v.
FRANCISCO CARBAJAL ALVIDREZ, Defendant.

          PITARO & FUMO, CHTD. THOMAS F. PITARO, ESQ. ATTORNEY FOR DEFENDANT THOMAS F. PITARO, ESQ. ATTORNEY FOR DEFENDANT

          DANIEL G BOGDEN UNITED STATES ATTORNEY SUSAN CUSHMAN, ESQ. ASSISTANT UNITED STATES ATTORNEYS

          STIPULATION AND ORDER TO CONTINUE SENTENCING

          RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE

         IT IS HEREBY STIPULATED by and between FRANCISCO CARBAJAL ALVIDREZ, Defendant, by and through his counsel THOMAS F. PITARO, ESQ, Defendant, by and through his counsel and the United States of America, SUSAN CUSHMAN, Assistant United States Attorney, that Sentencing in the above-captioned matter currently scheduled for June 8, 2017 at the hour of 2:00 p.m., vacated and continued for next week, or to a date and time to be set by this Honorable Court.

         This Stipulation is entered into for the following reasons:

         1. Counsel has a family emergency and needs to accompany his wife at the hospital.

         2. Defendant is in custody. Counsel for defendant has spoken with his client he has no objection to this continuance.

         3. Counsel understands that his presence is required to appear before the Court since he is the attorney of record.

         4. Counsel has spoken to Assistant United States Attorney Susan Cushman and she has no opposition to the continuance.

         5. Denial for this request for continuance would deny the parties herein time and the opportunity within which to effectively and thoroughly research and prepare for trial in this case, taking into account the exercise of due diligence and continuity of counsel.

         6. Additionally, denial of this request for continuance would result in a miscarriage of justice.

         7. For all the above-stated reasons, the ends of justice would best be served by a continuance of the sentencing date.

         8. This is the first request for a continuance of the trial date in this case. DATED: June 7, 2017

         FINDINGS ...


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