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United States v. Guzman-Hernandez

United States District Court, D. Nevada

January 15, 2020

UNITED STATES OF AMERICA, Plaintiff,
v.
PABLO GUZMAN-HERNANDEZ, Defendant.

          JARED L. GRIMMER, ESQ. ASSISTANT UNITED STATES ATTORNEY COUNSEL FOR THE UNITED STATES

          DAVID R. FISCHER, ESQ. COUNSEL FOR DEFENDANT GUZMAN-HERNANDEZ

          STIPULATION TO CONTINUE HEARING FOR SENTENCING (FIRST REQUEST)

          HONORABLE JAMES C. MAHAN UNITED STATES DISTRICT JUDGE.

         IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, Jared L. Grimmer, Esq., Assistant United States Attorney, and David R. Fischer, Esq., counsel for defendant PABLO GUZMAN-HERNANDEZ, that the Hearing for Sentencing in the above-captioned matter set for Tuesday, February 25, 2020, at 10:30 A.M., be vacated and continued to a date and time convenient to the Court but no earlier than thirty (30) days.

         This Stipulation for the continuance is entered into for the following reasons:

         1. This is a request by counsel for the Defendant, PABLO GUZMAN-HERNANDEZ;

         2. The additional time requested by this Stipulation is reasonable pursuant to Federal Rule of Criminal Procedure 32(b)(2), which states that "the court may, for good cause, change any limits prescribed in this rule";

         3. Counsel requests this additional time in order to allow adequate time to research Sentencing issues and to prepare for the sentencing hearing;

         4. Counsel communicated with the Defendant, PABLO GUZMAN-HERNANDEZ, who is currently in custody at the Nevada Southern Detention Center, and GUZMAN-HERNANDEZ agrees with the continuance;

         5. This is the first request for a continuance filed herein.

         WHEREFORE, for the foregoing reasons, the ends of justice would best be served by a continuance of the Sentencing Hearing to be set to a date and time convenient to the Court but no earlier than thirty (30) days.

         CERTIFICATE OF ELECTRONIC SERVICE

         I HEREBY CERTIFY that I am an employee or agent of the LAW OFFICE OF DAVID R. FISCHER and am a person of such age and discretion as to be competent to serve papers and that, on the 13th day of January 2020, I served a copy of the above and foregoing STIPULATION TO CONTINUE SENTENCING HEARING in the following manner(s):

         [X] ELECTRONIC SERVICE: Pursuant to Local Rule IC 4-1 of the United States District Court for the District of Nevada, the above-referenced document was electronically filed and served on all appearing parties through the ...


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