Stipulation to Continue Sentencing Hearing — No. 2:20-cr-00286 (Dkt. 135, D. Nev.)

Summary

A three-page Stipulation to Continue Sentencing Hearing (Second), with order, Document 135, filed 01/05/24 in United States v. Karen Chapon, Case No. 2:20-cr-286 JCM, in the U.S. District Court for the District of Nevada, signed on the 4th day of January, 2024 by Lisa A. Rasmussen for Chapon and Assistant United States Attorney Jessica Oliva. Sentencing was first set for November 29, 2023; after Rasmussen was appointed, a first stipulation reset it to January 12, 2024. Rasmussen moved to withdraw on November 6, 2023, the court denied the motion on November 17, 2023, and a family bereavement over the Christmas holiday consumed the following weeks, so she asks for a late February date, which the government does not oppose. District Judge James C. Mahan's order of January 5, 2024 resets sentencing to February 26, 2024 at 10:00 a.m.

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“Stipulation to Continue Sentencing Hearing — No. 2:20-cr-00286 (Dkt. 135, D. Nev.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-continue-sentencing-hearing-no-2-20-cr-00286-dkt-135-d-b4026ac15f/, SHA-256 3fc374e544e67e078ffc8f3efe1c2a90574782b10539f662748782dab3f30d2b.

Full text

Case 2:20-cr-00286-JCM-NJK Document 135 Filed 01/05/24 Page 1 of 3

1 Lisa A. Rasmussen, Esq.
2 Nevada Bar No. 7491
THE LAW OFFICES OF KRISTINA
3
WILDEVELD & ASSOCIATES
4 550 E. Charleston Blvd., Suite A
Las Vegas, NV 89104
5
(702) 222-0007 (T) | (702)222-0001
6 Email: Lisa@VeldLaw.com
7
Attorneys for Defendant Karen Chapon
8

9
UNITED STATES DISTRICT COURT
10

11 DISTRICT OF NEVADA

12
UNITED STATES OF AMERICA, Case No.: 2:20-cr-286 JCM
13
Plaintiff,
14
STIPULATION TO CONTINUE
15
vs. SENTENCING HEARING
(SECOND)
16 KAREN CHAPON,
17
Defendant.
18

19 The parties, Karen Chapon, by and her counsel, Lisa A. Rasmussen, Esq., and the
20 United States, by and through its counsel, Assistant United States Attorney Jessica Oliva,
21 hereby stipulate as follows:
22
1. Sentencing was originally set for November 29, 2023 in this matter.
23
2. Ms. Rasmussen was appointed to represent Ms. Chapon on October 10,
24
2023. ECF 124. At that time the parties entered into a stipulation to continue the
25
sentencing to permit Ms. Rasmussen time to get up to speed with Ms. Chapon and to
26
properly prepare for sentencing. See Stipulation (First) at ECF 125. This resulted in the
27
sentencing being reset to January 12, 2024, it’s presently scheduled date. ECF 126.
28
STIPULATION TO CONTINUE SENTENCING HEARING(SECOND) - 1
Case 2:20-cr-00286-JCM-NJK Document 135 Filed 01/05/24 Page 2 of 3

1
3. On November 6, 2023, the undersigned filed a motion to withdraw in
2
consultation with Ms. Chapon. ECF 127.
3
4. On November 17, 2023, this Court denied the Motion. ECF 129.
4
5. Ms. Rasmussen was out of the country from November 27, 2023 until
5
December 2, 2023 and she discussed the denial with Ms. Chapon in early December when
6
she returned.
7
6. After consultation with Ms. Chapon, Ms. Rasmussen filed a notice that she
8
would proceed as counsel for Ms. Chapon essentially notifying the court that she would
9

10
not refile another motion that addressed some of the infirmities the court pointed out

11 from the initial motion. ECF 131.

12 7. It was not until this point that Ms. Rasmussen began working with Ms.

13 Chapon on sentencing issues and other issued that needed to be addressed.

14 8. On December 23, 2023 Ms. Rasmussen’s family suffered the tragic loss of

15 her 13-year-old nephew during an accident while her family was gathered for the
16 Christmas holiday. As a result, Ms. Rasmussen’s efforts have been devoted to addressing
17 her family’s crisis and loss. The combination of losing time with Ms. Chapon in
18 November and early December and not have sufficient time between the Christmas
19 holiday and today to work on Ms. Chapon’s sentencing issues requires her to ask for an
20 extension of time to properly prepare for Ms. Chapon’s sentencing hearing.
21
9. Ms. Rasmussen is requesting a date in late February.
22
10. The government is not opposed to this request.
23
11. Ms. Chapon is on pretrial release and is not opposed to this request.
24
12. Denial of this request would cause prejudice to both the government and
25
the defendant.
26
Dated this 4th day of January, 2024.
27

28 The Law Offices of Kristina Wildeveld & Associates,
STIPULATION TO CONTINUE SENTENCING HEARING(SECOND) - 2
Case 2:20-cr-00286-JCM-NJK Document 135 Filed 01/05/24 Page 3 of 3

2 /s/ Lisa A. Rasmussen
___________________________
3
LISA A. RASMUSSEN, ESQ.
4 Counsel for Karen Chapon
5

7
JASON FRIERSON,
United States Attorney
8 District of Nevada
9
/s/ Jessica Oliva
10
________________________________
11 BY: JESSICA OLIVA
Assistant United States Attorney
12

13
ORDER
14

15
Pursuant to the Stipulation of the parties, and good cause appearing,

16 IT IS FURTHER ORDERED that the Sentencing hearing presently

17 scheduled for January 12, 2024 shall be vacated and reset to February 26, 2024, at

18 10:00 a.m.
DATED January 5, 2024.
19
___________________________________
20
The Honorable James C. Mahan
21 United States District Judge
22

28
STIPULATION TO CONTINUE SENTENCING HEARING(SECOND) - 3

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