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Stipulation to Continue Sentencing Hearing — No. 2:22-cr-00286 (Dkt. 24, D. Nev.)

Summary

A three-page Stipulation to Continue Sentencing Hearing, marked First Request, with order, Document 24, filed 05/16/23 in United States v. Mikaela Cuevas, Case No. 2:22-cr-00286-CDS-BNW, in the U.S. District Court for the District of Nevada. Assistant Federal Public Defender Aden Kebede for Cuevas and Assistant United States Attorney Kimberly Frayn for United States Attorney Jason M. Frierson agree that the sentencing hearing set for June 5, 2023 be vacated and continued to a date no sooner than thirty (30) days away because defense counsel is still developing the mitigation package; the defendant is out of custody and agrees. Counsel signed on the 15th day of May, 2023, and on the 16th day of May, 2023 the court continued the hearing from June 5, 2023 at 1:30 p.m. to July 13, 2023 at 11:00 a.m. in LV Courtroom 6B before Judge Cristina D. Silva.

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Cite this document

“Stipulation to Continue Sentencing Hearing — No. 2:22-cr-00286 (Dkt. 24, D. Nev.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-continue-sentencing-hearing-no-2-22-cr-00286-dkt-24-d-n-e75f330a07/, SHA-256 0a00791d32c892f34c58810cb3bee0e6796c380bcdfc9b74c4170094b616e19d.

Full text

        Case 2:22-cr-00286-CDS-BNW Document 24 Filed 05/16/23 Page 1 of 3




 1   RENE L. VALLADARES
     Federal Public Defender
 2   State Bar No. 11479
     ADEN KEBEDE
 3   Assistant Federal Public Defender
     Nevada State Bar No. 15581
 4   411 E. Bonneville, Ste. 250
     Las Vegas, Nevada 89101
 5   (702) 388-6577/Phone
     (702) 388-6261/Fax
 6   Aden_Kebede@fd.org
 7   Attorney for Mikaela Cuevas
 8
                                  UNITED STATES DISTRICT COURT
 9
                                       DISTRICT OF NEVADA
10
11   UNITED STATES OF AMERICA,                           Case No. 2:22-cr-00286-CDS-BNW
12                   Plaintiff                           STIPULATION TO CONTINUE
13                                                       SENTENCING HEARING
            v.
                                                         (First Request)
14   MIKAELA CUEVAS,
15                  Defendant
16
17          IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson,
18   United States Attorney, and Kimberly Frayn, Assistant United States Attorney, counsel for the
19   United States of America, and Rene L. Valladares, Federal Public Defender, and Aden Kebede,
20   Assistant Federal Public Defender, counsel for Mikaela Cuevas, that the Sentencing Hearing
21   currently scheduled on June 5, 2023, be vacated and continued to a date and time convenient to
22   the Court, but no sooner than thirty (30) days.
23          This Stipulation is entered into for the following reasons:
24          1.      Defense counsel is developing its mitigation package and needs additional time
25   to prepare for sentencing.
26          2.      The defendant is out of custody and agrees with the need for the continuance.
       Case 2:22-cr-00286-CDS-BNW Document 24 Filed 05/16/23 Page 2 of 3




 1     3. The parties agree to the continuance.
 2         This is the first request for a continuance of the sentencing hearing.
 3         DATED this 15th day of May, 2023.
 4
 5   RENE L. VALLADARES                              JASON M. FRIERSON
     Federal Public Defender                         United States Attorney
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     By /s/ Aden Kebede                              By /s/ Kimberly Frayn
 8   ADEN KEBEDE                                     KIMBERLY FRAYN
     Assistant Federal Public Defender               Assistant United States Attorney
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                                                     2
        Case 2:22-cr-00286-CDS-BNW Document 24 Filed 05/16/23 Page 3 of 3




 1                              UNITED STATES DISTRICT COURT

 2                                  DISTRICT OF NEVADA

 3
     UNITED STATES OF AMERICA,                        Case No. 2:22-cr-00286-CDS-BNW
 4
                    Plaintiff                         ORDER
 5
            v.
 6
     MIKAELA CUEVAS,
 7
                   Defendant
 8
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10          IT IS THEREFORE ORDERED that the sentencing hearing currently scheduled for

11   Monday, June 5, 2023, at 1:30 p.m., is vacated and continued to July 13, 2023 at the hour

12   of 11:00 a.m. in LV Courtroom 6B before Judge Cristina D. Silva.

13          DATED this 16th day of May, 2023.

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                                                UNITED STATES DISTRICT JUDGE
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                                                  3


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