Stipulation to Continue Revocation Hearing — United States v. Robinson (Dkt. 45, D. Nev.)

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A stipulation to continue a revocation hearing (second request) in United States v. Jonathan Millard Robinson, Case No. 2:22-cr-00133-RFB-EJY, in the U.S. District Court for the District of Nevada, filed April 11, 2025 as Document 45. It is entered by U.S. Attorney Sigal Chattah and Assistant U.S. Attorney Kimberly M. Frayn with Federal Public Defender Rene L. Valladares and Assistant Federal Public Defender Rick Mula. The parties ask that the revocation hearing set for April 16, 2025 be moved to May 23, 2025, stating that the hearing will likely be contested, that government counsel is unavailable on April 16, and that the defendant is out of custody. A proposed order for the judge's signature follows.

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Case 2:22-cr-00133-RFB-EJY Document45- Filed 04/11/25 Pagelof3

      RENE L. VALLADARES
      Federal Public Defender
      State Bar No. 11479
      RICK MULA
 Rh WwW WN   Assistant Federal Public Defender
      411 E. Bonneville, Ste. 250
      Las Vegas, Nevada 89101
      (702) 388-6577/Phone
      (702) 388-6261/Fax
      Rick Mula@fd.org

      Attorney for Jonathan Millard Robinson
 Co Oo NY WB NN

                              UNITED STATES DISTRICT COURT

                                     DISTRICT OF NEVADA

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      UNITED STATES OF AMERICA,                      Case No. 2:22-cr-00133-RFB-EJY
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                   Plaintiff,                        STIPULATION TO CONTINUE
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                                                     REVOCATION HEARING
13           v.                                      (Second Request)

      JONATHAN MILLARD ROBINSON,
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                   Defendant.
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             IT IS HEREBY STIPULATED AND AGREED, by and between Sigal Chattah, United
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      States Attorney, and Kimberly M. Frayn, Assistant United States Attorney, counsel for the
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      United States of America, and Rene L. Valladares, Federal Public Defender, and Rick Mula,
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      Assistant Federal Public Defender, counsel for Jonathan Millard Robinson, that the Revocation
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      Hearing currently scheduled on April 16, 2025, be vacated and continued to May 23, 2025.
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             This Stipulation is entered into for the following reasons:
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             1.     The pending revocation hearing is scheduled for April 16, 2025, and as the
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      parties continue to seek a resolution, it will likely be contested. Government’s counsel is
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      unavailable to proceed with the revocation hearing on April 16. As a result, the parties seek a
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      continuance to allow both parties to prepare for the contested revocation hearing.
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             2.     The defendant is out of custody.

Rh WwW WN

Co Oo NY WB NN

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Case 2:22-cr-00133-RFB-EJY Document45- Filed 04/11/25 Page 2of3

3. The parties agree to the continuance.
This is the second request for a continuance of the revocation hearing.

DATED this 11th day of April, 2025.

RENE L. VALLADARES SIGAL CHATTAH

Federal Public Defender United States Attorney

By /s/ Rick Mula By /s/ Kimberly M. Frayn

RICK MULA KIMBERLY M. FRAYN
Assistant Federal Public Defender Assistant United States Attorney


       Case 2:22-cr-00133-RFB-EJY            Document 45        Filed 04/11/25   Page 3 of 3




 1                               UNITED STATES DISTRICT COURT

 2                                     DISTRICT OF NEVADA

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     UNITED STATES OF AMERICA,                              Case No. 2:22-cr-00133-RFB-EJY
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                    Plaintiff,                              ORDER
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            V.
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     JONATHAN MILLARD ROBINSON,
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                    Defendant.
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10          IT IS THER EFOR E OR DER ED that the revocation hearing currently scheduled for

11   April 16, 2025 at 10:45 a.m., be vacated and continued to May 23, 2025 at the hour of 9:15

12   a.m.; or to a time and date convenient to the court.

13          DATED this 11th day of April, 2025.

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                                                   UNITED STATES DISTRICT JUDGE
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