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Stipulation to Continue Sentencing Hearing — No. 2:21-cr-00027 (Dkt. 61, D. Nev.)

Summary

A three-page Stipulation to Continue Sentencing Hearing, marked First Request, with order, Document 61, filed 11/23/21 in United States v. Jorge Abramovs, Case No. 2:21-cr-00027-RFB-DJA, in the U.S. District Court for the District of Nevada. Assistant Federal Public Defender Margaret W. Lambrose for Abramovs and Assistant United States Attorney Jessica Oliva for Acting United States Attorney Christopher Chiou agree that the sentencing hearing set for January 6, 2022 at 11:00 a.m. be vacated and continued to a date no sooner than forty-five (45) days away, because defense counsel needs more time to investigate and gather mitigation; the defendant is in custody and agrees. Counsel signed on the 22nd day of November, 2021, and on the 23rd day of November, 2021 District Judge Richard F. Boulware, II continued the hearing to March 3, 2022 at 9:00 a.m.

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“Stipulation to Continue Sentencing Hearing — No. 2:21-cr-00027 (Dkt. 61, D. Nev.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-continue-sentencing-hearing-no-2-21-cr-00027-dkt-61-d-n-c3eec561b0/, SHA-256 5e992e13537d2fd45b8056818accdd22a731acedde400a573da434f1ef26b8e8.

Full text

         Case 2:21-cr-00027-RFB-DJA Document 61 Filed 11/23/21 Page 1 of 3




 1   RENE L. VALLADARES
     Federal Public Defender
 2   State Bar No. 11479
     MARGARET W. LAMBROSE
 3   Assistant Federal Public Defender
     Nevada State Bar No. 11626
 4   411 E. Bonneville, Ste. 250
     Las Vegas, Nevada 89101
 5   (702) 388-6577/Phone
     (702) 388-6261/Fax
 6   Maggie_Lambrose@fd.org

 7   Attorney for Jorge Abramovs

 8
                                 UNITED STATES DISTRICT COURT
 9
                                       DISTRICT OF NEVADA
10
11   UNITED STATES OF AMERICA,                           Case No. 2:21-cr-00027-RFB-DJA

12                  Plaintiff,                               STIPULATION TO CONTINUE
                                                               SENTENCING HEARING
13          v.
                                                                    (First Request)
14   JORGE ABRAMOVS,

15                  Defendant.

16
17          IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou,
18   United States Attorney, and Jessica Oliva, Assistant United States Attorney, counsel for the
19   United States of America, and Rene L. Valladares, Federal Public Defender, and Margaret W.
20   Lambrose, Assistant Federal Public Defender, counsel for Jorge Abramovs, that the Sentencing
21   Hearing currently scheduled on January 6, 2022 at 11:00 a.m., be vacated and continued to a
22   date and time convenient to the Court, but no sooner than forty-five (45) days.
23          This Stipulation is entered into for the following reasons:
24          1.      Counsel for the defendant needs additional time to conduct additional
25   investigation and gather mitigation information for Mr. Abramovs, which is relevant to the
26   sentencing disposition of this case.
       Case 2:21-cr-00027-RFB-DJA Document 61 Filed 11/23/21 Page 2 of 3




 1        2.     The defendant is in custody and agrees with the need for the continuance.
 2        3.     The parties agree to the continuance.
 3        This is the first request for a continuance of the sentencing hearing.
 4        DATED this 22nd day of November, 2021.
 5
 6   RENE L. VALLADARES                             CHRISTOPHER CHIOU
     Federal Public Defender                        Acting United States Attorney
 7
 8      /s/ Margaret W. Lambrose                       /s/ Jessica Oliva
     By_____________________________                By_____________________________
 9   MARGARET W. LAMBROSE                           JESSICA OLIVA
     Assistant Federal Public Defender              Assistant United States Attorney
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                                                    2
        Case 2:21-cr-00027-RFB-DJA Document 61 Filed 11/23/21 Page 3 of 3




 1                             UNITED STATES DISTRICT COURT

 2                                  DISTRICT OF NEVADA

 3
     UNITED STATES OF AMERICA,                       Case No. 2:21-cr-00027-RFB-DJA
 4
                  Plaintiff,                         ORDER
 5
           v.
 6
     JORGE ABRAMOVS,
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                  Defendant.
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10         IT IS THEREFORE ORDERED that the sentencing hearing currently scheduled for

11   Thursday, January 6, 2022 at 11:00 a.m., be vacated and continued to March 3, 2022
                                                                          ________________ at

12   the hour of 9  00 a
                ___:___ __.m.

13                   23rd day of November, 2021.
           DATED this ___

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                                              RICHARD F. BOULWARE, II
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                                              UNITED STATES DISTRICT JUDGE
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                                                 3


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