United States District Court, D. Nevada
ELIESON UNITED STATES ATTORNEY DISTRICT OF NEVADA JARED
GRIMMER ASSISTANT UNITED STATES ATTORNEY ATTORNEYS FOR
PLAINTIFF, UNITED STATES OF AMERICA
GENTILE CRISTALLI MILLER ARMENI SAVARESE PAOLA M. ARMENI
ATTORNEY FOR DEFENDANT, JOEL SHANNON SMITH
STIPULATION AND ORDER TO CONTINUE ARRAIGNMENT/PLEA
J. KOPPE, UNITED STATES MAGISTRATE JUDGE
IS HEREBY STIPULATED by and between Joel Shannon
Smith (“Mr. Smith”), Defendant, by and through
his counsel, Paola M. Armeni, Esq., of the law firm of
Gentile Cristalli Miller Armeni Savarese and the Plaintiff,
United States of America, by and through Dayle Elieson,
United States Attorney, and, Jared Grimmer, Assistant United
States Attorney, that the Arraignment/Plea on the Superseding
Indictment in the above-captioned matter, currently scheduled
for July 12, 2018, at the hour of 1:30 p.m. be vacated. The
Parties respectfully request the hearing be continued to the
afternoon of July 13, 2018 or in the alternative July
Stipulation is entered into for the following reasons:
July 3, 2018, a Superseding Indictment was filed against Mr.
Smith. (ECF. 48).
Arraignment/Plea on the Superseding Indictment has been set
for July 12, 2018 at 1:30p.m. in front of the Honorable
Magistrate Judge Nancy J. Koppe. (ECF. 50).
Paola M. Armeni, will be out of the jurisdiction on July 12,
2018 teaching at the Trial Academy at the Annual State Bar of
Nevada Conference in Chicago, Illinois. Therefore, she is
unavailable to appear at the current Arraignment/Plea on
behalf of her client, Mr. Smith.
short continuance of the Arraignment/Plea is necessary to
ensure Mr. Smith's counsel is present at this court
appearance, protecting his constitutional right to assistance
Smith has appeared in this case and is in custody and, along
with the government, agrees to a continuance.
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.
all the above-stated reasons, the ends of justice would be
best served by a short continuance of the Arraignment/Plea.
is the first request for a continuance of the
OF FACT, ...