Stipulation to Continue Sentencing Hearing — No. 2:21-cr-00027 (Dkt. 74, D. Nev.)

Summary

A three-page Stipulation to Continue Sentencing Hearing, Document 74, filed 01/20/22 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 Trial Attorney Joseph S. McFarlane for Acting United States Attorney Christopher Chiou agree that the sentencing hearing set for March 3, 2022 be vacated and continued to a date no sooner than sixty (60) days later. While Abramovs was held at the Henderson Detention Center defense counsel could not readily meet him or review the presentence report with him; he has since moved to the Nevada Southern Detention Center. Counsel signed on the 18th day of January, 2022, and on the 20th day of January, 2022 District Judge Richard F. Boulware, II continued the hearing to May 5, 2022 at 9:00 a.m.

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        Case 2:21-cr-00027-RFB-DJA Document 74 Filed 01/20/22 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
 9                       UNITED STATES DISTRICT COURT

10                              DISTRICT OF NEVADA

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     UNITED STATES OF AMERICA,                      Case No. 2:21-cr-00027-RFB-DJA
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                 Plaintiff,                        STIPULATION TO CONTINUE
13                                                   SENTENCING HEARING
           v.
14                                                       (Second Request)
     JORGE ABRAMOVS,
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                 Defendant.
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           IT IS HEREBY STIPULATED AND AGREED, by and between Christopher
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     Chiou, Acting United States Attorney, and Joseph S. McFarlane, Trial Attorney,
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20   counsel for the United States of America, and Rene L. Valladares, Federal Public

21   Defender, and Margaret W. Lambrose, Assistant Federal Public Defender, counsel

22   for Jorge Abramovs, that the Sentencing Hearing currently scheduled on March 3,

23   2022, be vacated and continued to a date and time convenient to the Court, but no

24   sooner than sixty (60) days from March 3, 2022.

25         This Stipulation is entered into for the following reasons:
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        Case 2:21-cr-00027-RFB-DJA Document 74 Filed 01/20/22 Page 2 of 3




 1         1.       While Mr. Abramovs was housed at the Henderson Detention Center
 2   it was extremely difficult for defense counsel to meet with him. As such, defense
 3   counsel has been unable to confer with Mr. Abramovs about the presentence
 4   investigation report and submit informal objections on his behalf.              As
 5   Mr. Abramovs is now back at the Nevada Southern Detention Center, defense
 6   counsel is hopeful that these communication problems will no longer be an issue.
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     However, a continuance is still necessary to allow defense counsel adequate time
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     to review the PSR with Mr. Abramovs and prepare for sentencing.
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           2.       The defendant is in custody and agrees with the need for the
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     continuance.
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           3.       The parties agree to the continuance.
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           This is the second request for a continuance of the sentencing hearing.
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           DATED this 18th day of January, 2022.
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     RENE L. VALLADARES                         CHRISTOPHER CHIOU
16   Federal Public Defender                    Acting United States Attorney
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        /s/ Margaret W. Lambrose                   /s/ Joseph S. McFarlane
18   By_____________________________            By_____________________________
19   MARGARET W. LAMBROSE                       JOSEPH S. MCFARLANE
     Assistant Federal Public Defender          Trial Attorney
20                                              Fraud Section, Criminal Division
                                                U.S. Department of Justice
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                                                2
        Case 2:21-cr-00027-RFB-DJA Document 74 Filed 01/20/22 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
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           v.
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     JORGE ABRAMOVS,
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                 Defendant.
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           IT IS THEREFORE ORDERED that the sentencing hearing currently
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     scheduled for Thursday, March 3, 2022 at 9:00 a.m., be vacated and continued to
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      May 5, 2022
     ________________                 9 00 __.m.
                      at the hour of ___:___ a
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           DATED this20th
                      ___ day of January, 2022.
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16                                        RICHARD F. BOULWARE, II
17                                        UNITED STATES DISTRICT JUDGE

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                                             3


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