United States District Court, D. Nevada
W. MYHRE ACTING UNITED STATES ATTORNEY KATHRYN C. NEWMAN
Assistant United States Attorney Attorneys for Plaintiff
UNITED STATES OF AMERICA
GENTILE CRISTALLI, MILLER ARMENI SAVARESE, MICHAEL V.
CRISTALLI, VINCENT SAVARESE, III LAUREN E. PAGLINI Attorneys
for Defendant, Robert Buckhannon
STIPULATION AND ORDER TO CONTINUE ROBERT
C. MAHAN, UNITED STATES DISTRICT COURT.
IS HEREBY STIPULATED AND AGREED by and between
Steven W. Myhre, Acting United States Attorney, Kathryn C.
Newman, Esq., Assistant United States Attorney; Michael V.
Cristalli, Esq., Vincent Savarese III, Esq., and Lauren E.
Paglini, Esq., of the law firm of Gentile Cristalli Miller
Armeni Savarese, attorneys for Defendant, Robert Buckhannon
(hereinafter "Mr. Buckhannon"), that the sentencing
currently scheduled for the 31st day of October,
2017, at the hour of 10:00 a.m., in Courtroom 6A of the
United States District Court, District of Nevada, be vacated
and continued to a date and time convenient to this Honorable
Stipulation is entered into for the following reasons:
1. Counsel for Mr. Buckhannon did not receive the Revised
Presentence Investigation Report until late in the day on
Monday, October 23, 2017.
2. Pursuant to Local Rule 32, Mr. Buckhannon's Objections
to the Revised Presentence Investigation Report and the
Sentencing Memorandum are both currently due on Tuesday,
October 24, 2017.
3. Counsel for Mr. Buckhannon have not had sufficient time to
research, prepare and file the appropriate Objections to the
Revised Presentence Investigation Report and Sentencing
Memorandum on Mr. Buckhannon's behalf.
4. Mr. Buckhannon is out of custody. Mr. Buckhannon has no
objection to the continuance sought. Assistant United States
Attorney, Kathryn Newman, Esq. has no objection to this
continuance of the sentence.
5. The additional time requested herein is not sought for
purposes of delay and the denial of this request for a
continuance could result in a miscarriage of justice.
6. For all the above-stated reasons, the ends of justice
would be best served by the continuance of the deadlines of
Mr. Buckhannon's sentencing.
7. That this is the first request for a continuance of Mr.
Buckhannon's sentencing hearing.
OF FACT, CONCLUSION OF LAW AND ORDER
upon the pending Stipulation of counsel, and good cause