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United States v. Franco-Ramos

United States District Court, D. Nevada

October 30, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
PIERRE FRANCO-RAMOS and VICTOR VAZQUEZ, Defendants.

          TODD M. LEVENTHAL COUNSEL FOR: VICTOR VAZQUEZ

          DANIEL R. SCHIESS ASSISTANT UNITED STATES ATTORNEY

          CRAIG MUELLER COUNSEL FOR: PIERRE FRANCO-RAMOS

          STIPULATION TO CONTINUE SENTENCING (SECOND REQUEST)

          RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE.

         IT IS HEREBY STIPULATED AND AGREED by and between Nicholas A. Trutanich, United States Attorney, and Daniel R. Schiess, Assistant United States Attorney, counsel for the United States of America, Todd M. Leventhal, Esq., counsel for Victor Vazquez, and Craig Mueller, Esq., counsel for Pierre Franco- Ramos, that the Sentencing currently scheduled for October 31, 2019 at 3:00 p.m. be vacated and set to a date and time convenient to this Court.

         The Stipulation is entered into for the following reasons:

         1. Attorney Todd Leventhal will be out of Jurisdiction the following days: 10/31/19 -11/4/19 2. The additional time requested herein is not sought for purposes of delay, but merely to allow counsel for Defendant Victor Vazquez to timely appear at the hearing.

         3. The defendant is not incarcerated and does not object to the continuance.

         4. The parties agree to the continuance.

         This is the second stipulation to continue Sentencing.

         FINDINGS OF FACT. CONCLUSIONS OF LAW AND ORDER

         FINDINGS OF FACT

         Based on the pending stipulation of counsel, and good cause appearing ...


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