Case 2:21-cr-00161-APG-DJA Document 44 Filed 08/24/22 Page 1 of 3
1 RENE L. VALLADARES
Federal Public Defender
2 Nevada State Bar No. 11479
ADEN KEBEDE
3 Assistant Federal Public Defender
411 E. Bonneville, Ste. 250
4 Las Vegas, Nevada 89101
(702) 388-6577/Phone
5 (702) 388-6261/Fax
Aden_Kebede@fd.org
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7 Attorney for Jonathan Robinson
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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11 UNITED STATES OF AMERICA, Case No. 2:21-cr-00161-APG-DJA
12 Plaintiff, STIPULATION TO CONTINUE
REVOCATION HEARING
13 v.
(Eighth Request)
14 JONATHAN ROBINSON,
15 Defendant.
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17 IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson,
18 United States Attorney, and Edward G. Veronda, Assistant United States Attorney, counsel for
19 the United States of America, and Rene L. Valladares, Federal Public Defender, and
20 Aden Kebede, Assistant Federal Public Defender, counsel for Jonathan Robinson, that the
21 Revocation Hearing currently scheduled on September 7, 2022 at 9:30 a.m., be vacated and
22 continued to a date and time convenient to the Court, but no sooner than sixty (60) days.
23 This Stipulation is entered into for the following reasons:
24 1. The parties have reached a resolution to the revocation as well as some of the
25 underlying conduct giving rise to the petition.
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Case 2:21-cr-00161-APG-DJA Document 44 Filed 08/24/22 Page 2 of 3
1 2. Mr. Robinson recently entered a guilty plea in Case No. 2:22-cr-00133-RFB-
2 EJY. Both parties agree that the revocation hearing should follow the sentencing in the new
3 case.
4 3. Because the joint recommended sentence for the revocation is 12 months
5 consecutive to the sentence in the new case, if this Court follows the parties’ joint
6 recommendation, the Court cannot officially enter the sentence until Mr. Robinson is sentenced
7 on the new criminal charges. Additionally, Mr. Robinson cannot admit to the criminal charges
8 in the revocation hearing before the Judgment is entered in the new case.
9 4. The defendant is in custody and agrees with the need for the continuance.
10 5. The parties agree to the continuance.
11 This is the eighth request for a continuance of the revocation hearing.
12 DATED this 22nd day of August, 2022.
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14 RENE L. VALLADARES JASON M. FRIERSON
Federal Public Defender United States Attorney
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16 /s/ Aden Kebede /s/ Edward G. Veronda
By_____________________________ By_____________________________
17 ADEN KEBEDE EDWARD G. VERONDA
Assistant Federal Public Defender Assistant United States Attorney
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Case 2:21-cr-00161-APG-DJA Document 44 Filed 08/24/22 Page 3 of 3
1 UNITED STATES DISTRICT COURT
2 DISTRICT OF NEVADA
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UNITED STATES OF AMERICA, Case No. 2:21-cr-00161-APG-DJA
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Plaintiff, ORDER
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v.
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JONATHAN ROBINSON,
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Defendant.
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10 IT IS THEREFORE ORDERED that the revocation hearing currently scheduled
11 for Wednesday, September 7, 2022 at 9:30 a.m., be vacated and continued to November 9,
12 2022 at the hour of 1:30 p.m. in Courtroom 6C.
13 DATED this 24th day of August, 2022.
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UNITED STATES DISTRICT JUDGE
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