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Stipulation to Vacate Status Check — No. 2:22-cr-00286 (Dkt. 21, D. Nev.)

Summary

A three-page Joint Status Report and Stipulation to Vacate Status Check with order, Document 21, filed 04/21/23 in United States v. Mikaela Marie Cuevas, Case No. 2:22-cr-00286-CDS-BNW, in the U.S. District Court for the District of Nevada, signed April 20, 2023 by Assistant Federal Public Defender Aden Kebede for Cuevas and Assistant United States Attorney Kimberly Frayn for United States Attorney Jason M. Frierson. At a March 30, 2023 status conference to correct her PR bond, the government reported a new violation for driving without a driver's license, and the court set a status check for April 25, 2023 at 10:00 a.m. to confirm she had obtained one, inviting a notice if she did so sooner. Cuevas obtained her driver's license as of April 17, 2023, attached as Exhibit A, so the parties ask that the hearing be vacated, and the court so ordered on April 21, 2023.

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Cite this document

“Stipulation to Vacate Status Check — No. 2:22-cr-00286 (Dkt. 21, D. Nev.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-vacate-status-check-no-2-22-cr-00286-dkt-21-d-nev-f58efcb6ee/, SHA-256 d4c24fb51f70c365d8731c0bc8b54321d0707a815657397b39b783eb3fb4df77.

Full text

        Case 2:22-cr-00286-CDS-BNW Document 21 Filed 04/21/23 Page 1 of 3




 1   RENE L. VALLADARES
     Federal Public Defender
 2   State Bar No. 11479
     ADEN KEBEDE
 3   State Bar No. 15581
     Assistant Federal Public Defender
 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
                                                            JOINT STATUS REPORT AND
13          v.                                           STIPULATION TO VACATE STATUS
     MIKAELA MARIE CUEVAS,                                           CHECK
14
15                  Defendant

16
17          In compliance with this Court’s minute order ECF No. 14, Jason M. Frierson, United
18   States Attorney, and Kimberly Frayn, Assistant United States Attorney, counsel for the United
19   States of America, and Rene L. Valladares, Federal Public Defender, and Aden Kebede,
20   Assistant Federal Public Defender, counsel for Mikaela Cuevas, files this Status Report and
21   request to continue status hearing currently set for April 25, 2023, at 10am.
22          1.      On March 30, 2023, the parties came before the Court on a status conference to
23   correct information on Ms. Cuevas’ PR bond. At that hearing, the government informed the
24   Court as to Ms. Cuevas new violation for driving without a driver's license.
25          2.      Ms. Cuevas informed the Court she has an appointment to obtain her driver’s
26   license. The Court set a status conference to confirm Ms. Cuevas received her driver’s license
        Case 2:22-cr-00286-CDS-BNW Document 21 Filed 04/21/23 Page 2 of 3




 1   and informed Ms. Cuevas that should she receive her license before the scheduled status
 2   conference, she could file a notice providing the driver’s license in order to vacate the hearing.
 3          3.       Ms. Cuevas has obtained her driver’s license as of April 17, 2023. 1
 4          4.       Therefore, the parties respectfully request this Court vacate the status conference
 5   set for April 25, 2023 at 10:00 a.m.
 6          DATED: April 20, 2023.
 7    RENE L. VALLADARES                                JASON M. FRIERSON
      Federal Public Defender                           United States Attorney
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      By /s/ Aden Kebede                                By /s/ Kimberly Frayn _
10    ADEN KEBEDE                                       KIMBERLY FRAYN
      Assistant Federal Public Defender                 Assistant United States Attorney
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26          1
                See Exhibit A, Ms. Cuevas’ temporary driver’s license.
                                                     2
        Case 2:22-cr-00286-CDS-BNW Document 21 Filed 04/21/23 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,
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                          Defendant
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10          IT IS THEREFORE ORDERED that the status conference currently scheduled for

11   Tuesday, April 25, 2023, at 10:00 a.m., is vacated.

12          DATED: April 21, 2023
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                                                  UNITED STATES DISTRICT JUDGE
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