Stipulation to Continue Objections to Report and Recommendation Deadline (First Request) — United States v. Keyawn Lloyd Cook Jr., No. 2:19-cr-00313-GMN-NJK (Dkt. 33, D. Nev.)

Summary

In this stipulation filed 02/16/21 in United States of America v. Keyawn Lloyd Cook Jr., Case No. 2:19-cr-00313-GMN-NJK in the District of Nevada, Assistant Federal Public Defender Rebecca Levy and Assistant U.S. Attorney Jessica Oliva agree that the deadline for objections to the report and recommendation, set for February 17, 2021, be vacated and continued to March 10, 2021, and the government's response moved from March 3, 2021 to March 24, 2021. The stated reasons are that defense counsel needs more time to file objections and discuss them with the client, that the defendant is not incarcerated and does not object, and that the parties agree. It is the first request. The filed copy, Document 33 of 02/17/21, includes an order of District Judge Gloria M. Navarro dated the 17 day of February 2021 continuing the deadlines as stipulated.

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Full text

Case 2:19-cr-00313-GMN-NJK Document 32
33 Filed 02/16/21
02/17/21 Page 1 of 4

1 RENE L. VALLADARES
Federal Public Defender
2 Nevada State Bar No. 11479
REBECCA LEVY
3 Assistant Federal Public Defender
411 E. Bonneville, Ste. 250
4 Las Vegas, Nevada 89101
(702) 388-6577/Phone
5 (702) 388-6261/Fax
Rebecca_Levy@fd.org
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7 Attorney for Keyawn Lloyd Cook Jr.

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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. 2:19-cr-00313-GMN-NJK
12 Plaintiff, STIPULATION TO CONTINUE
13 OBJECTIONS TO REPORT AND
v.
RECOMMENDATION DEADLINE
14 KEYAWN LLOYD COOK JR., (First Request)
15 Defendant.
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17 IT IS HEREBY STIPULATED AND AGREED, by and between
18 Nicholas A. Trutanich, United States Attorney, and Jessica Oliva, Assistant United
19 States Attorney, counsel for the United States of America, and Rene L. Valladares,
20 Federal Public Defender, and Rebecca Levy, Assistant Federal Public Defender, counsel for
21 Keyawn Lloyd Cook Jr., that the objections to the report and recommendation currently
22 scheduled on February 17, 2021, be vacated and continued to March 10, 2021 and the
23 government’s response from March 3, 2021 to March 24, 2021.
24 The Stipulation is entered into for the following reasons:
25 1. Defense counsel needs additional time to file objections and discuss the
26 objections with her client.
Case 2:19-cr-00313-GMN-NJK Document 32
33 Filed 02/16/21
02/17/21 Page 2 of 4

1 2. The defendant is note incarcerated and does not object to the continuance.
2 3. The parties agree to the continuance.
3 4. Additionally, denial of this request for continuance could result in a miscarriage
4 of justice.
5 This is the first stipulation to continue filed herein.
6 DATED this 16th day of February 2021.
7 RENE L. VALLADARES NICHOLAS A. TRUTANICH
Federal Public Defender United States Attorney
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9 /s/ Rebecca Levy /s/ Jessica Oliva
By_____________________________ By_____________________________
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REBECCA LEVY JESSICA OLIVA
11 Assistant Federal Public Defender Assistant United States Attorney

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Case 2:19-cr-00313-GMN-NJK Document 32
33 Filed 02/16/21
02/17/21 Page 3 of 4

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

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UNITED STATES OF AMERICA, Case No. 2:19-cr-00313-GMN-NJK
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Plaintiff, FINDINGS OF FACT, CONCLUSIONS
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OF LAW AND ORDER
v.
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KEYAWN LLOYD COOK JR.,
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Defendant.
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10 FINDINGS OF FACT
11 Based on the pending Stipulation of counsel, and good cause appearing therefore, the
12 Court finds that:
13 1. Defense counsel needs additional time to file objections and discuss the
14 objections with her client.
15 2. The defendant is not incarcerated and does not object to the continuance.
16 3. The parties agree to the continuance.
17 4. Additionally, denial of this request for continuance could result in a miscarriage
18 of justice.
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Case 2:19-cr-00313-GMN-NJK Document 32
33 Filed 02/16/21
02/17/21 Page 4 of 4

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF NEVADA

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UNITED STATES OF AMERICA, Case No. 2:19-cr-00313-GMN-NJK
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Plaintiff, ORDER
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v.
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KEYAWN LLOYD COOK JR.,
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Defendant.
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10 Based on the Stipulation of counsel and good cause appearing,

11 IT IS THEREFORE ORDERED that the objections to the Report &

12 Recommendation currently scheduled on February 17, 2021, be vacated and continued to

13 March 10, 2021 and the government’s response from March 3, 2021 to March 24, 2021.

14 17 day of February 2021.
DATED this ____

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Gloria M. Navarro, District Judge
17 United States District Court
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