Motion to Authorize Funds for Travel to Attend Court Hearing — United States of America v. Alexander Hoyos Rivera, Case No. 2:23-cr-2-RFB-VCF (Dkt. 142, D. Nev.)
Summary
In this motion (Dkt. 142, filed 08/08/23) in United States of America v. Alexander Hoyos Rivera (D. Nev., Case No. 2:23-cr-2-RFB-VCF), defense attorney Ivette Amelburu Maningo asks the court to direct the United States Marshals Service to pay the defendant's airline costs, hotel, transportation and a per diem for meals to attend sentencing. The motion says Hoyos, who resides in Ohio and has been found indigent for purposes of representation, is to plead guilty under a plea agreement to conspiracy to commit mail fraud. The sentencing hearing set for July 25, 2023 was reset by the court for August 14, 2023 at 1:00 p.m., and travel arranged under an earlier order was cancelled when the earlier hearing was vacated. A proposed order attached to the motion would direct one-way travel from Ohio to Las Vegas and a per diem under 18 USC 4285.
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So Oo NY WBN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 1 of 6 LAW OFFICES OF IVETTE AMELBURU MANINGO IVETTE AMELBURU MANINGO, ESQ. NEVADA BAR NO.: 7076 400 S. Fourth Street, Ste. 500 Las Vegas, NV 89101 Tele.: (702) 793-4046 Fax: (844) 793-4046 Email: iamaningo@iamlawnv.com Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF NEVADA UNITED STATES OF AMERICA, CASE NO.: 2:23-cr-2-RFB-VCF Plaintiff, Vs. MOTION TO AUTHORIZE FUNDS FOR TRAVEL TO ATTEND COURT ALEXANDER HOYOS RIVERA, HEARING Defendant. COMES NOW, Defendant, ALEXANDER HOYOS RIVERA, by and through his attorney IVETTE AMELBURU MANINGO, ESQ. of THE LAW OFFICES OF IVETTE AMELBURU MANINGO, and moves to this Honorable Court for an Order directing the United States Marshals Service to arrange and pay for the Defendant’s airline costs, hotel accommodations, transportation, and a per diem for meals so that he can attend the Sentencing Hearing that is now scheduled for Tuesday, July 25, 2023, at 2:30 p.m. In support of this Motion, Defendant states as follows: 1. Pursuant to a Plea Agreement, Mr. Hoyos is to plead guilty to Conspiracy to Commit Mail Fraud in violation 18 U.S.C. §§ 1349. 2. Mr. Hoyos resides in the State of Ohio. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 2 of 6 3. The Sentencing Hearing in this matter was previously scheduled for Tuesday, July 25, 2023, at 2:30 p.m. but was reset by the Court for August 14, 2023 at 1:00 p.m. (Dkt. 136). 4. Mr. Hoyos has been found indigent for purposes of representation. He has limited resources and does not have sufficient funds to pay for accommodations to attend the Sentencing Hearing in person. 5. This Court previously entered an Order Granting Motion (Dkt. 126) to Authorize Funds for One-way Travel and Per Diem to Attend Court Sentencing Hearing (Dkt. 127) and entered an Order directing US Marshal Service to provide same (Dkt.128). Said travel was arranged but cancelled when the previously scheduled sentencing hearing was vacated. 6. As such, the undersigned counsel respectfully requests that the Court once order that arrangements be made and paid for by the US Marshal Service so that Mr. Hoyos can appear in person for his August 14, 2023 Sentencing Hearing as required by this Court. For the foregoing reasons, Defendant respectfully requests that this Court issue 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 3 of 6 an Order directing the Marshal’s Service to arrange and pay for Mr. Hoyos’ travel arrangements, hotel accommodations, transportation, and be provided with reasonable funds for meals. Respectfully submitted, /s| Ivette Amelburu Maningo IVETTE AMELBURU MANINGO, ESQ. NEVADA BAR NO.: 7076 400 S. Fourth Street, Ste. 500 Las Vegas, NV 89101 Tele.: (702) 793-4046 Fax: (844) 793-4046 Email‘iamaningo@iamlawnv.com 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 4 of 6 CERTIFICATE OF ELECTRONIC SERVICE The undersigned hereby certifies that on the 1st day of August, 2023 I served an electronic copy of the above DEFENDANT HOYOS RIVERA’S MOTION TO AUTHORIZE FUNDS FOR TRAVEL TO ATTEND SENTENCING HEARING to all parties of record via CM/ECF. /s/ Wildalia Coulson Employee of The Law Offices of Ivette Amelburu Maningo So Oo NY WBN 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 5 of 6 LAW OFFICES OF IVETTE AMELBURU MANINGO IVETTE AMELBURU MANINGO, ESQ. NEVADA BAR NO.: 7076 400 S. Fourth Street, Ste. 500 Las Vegas, NV 89101 Tele.: (702) 793-4046 Fax: (844) 793-4046 Email: iamaningo@iamlawnv.com Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF NEVADA UNITED STATES OF AMERICA, Plaintiff, vs. ALEXANDER HOYOS RIVERA, Defendant. CASE NO.: 2:23-cr-2-RFB-VCF ORDER DIRECTING UNITED STATES MARSHAL TO PROVIDE TRAVEL EXPENSES AND PER DIEM This matter having come before the Court on Motion of the Defendant, ALEXANDER HOYOS RIVERA, and it appearing that a Sentencing Hearing is scheduled for August 14, 2023 at 1:00 p.m., that Defendant Hoyos Rivera resides out of this district in Ohio, and that he is financially unable to provide for his airline, transporation, and meals while traveling to Las Vegas to attend his hearing, IT IS ORDERED that the United States Marshal Service shall, pursuant to 18 USC 4285, provide Defendant Hoyos Rivera with one-way travel accommodations from 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:23-cr-00002-RFB-VCF Document 142 Filed 08/08/23 Page 6 of 6 Ohio to Las Vegas and with a per diem for subsistence expenses while traveling to attend his Sentencing Hearing scheduled for August 14, 2023 at 1:00 p.m. at the United States District Court, District of Nevada, located in the Lloyd D. George Courthouse in Las Vegas, Nevada. Dated this 8th_ day of August, 2023 United States District Judge Respectfully submitted, /s/ Ivette Amelburu Maningo IVETTE AMELBURU MANINGO, ESQ. NEVADA BAR NO.: 7076 400 S. Fourth Street, Ste. 500 Las Vegas, NV 89101 Tele.: (702) 793-4046 Fax: (844) 793-4046 Email‘iamaningo@iamlawnv.com
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