Opinion
CASE NO. 2:10-CR-307-LDG-RJJ
05-23-2013
THE UNITED STATES OF AMERICA, Plaintiff, v. TIFFANY BAUTISTA, Defendant.
GORDON SILVER MICHAEL V. CRISTALLI Nevada Bar No. 6266 Attorney for Bautista
GORDON SILVER
MICHAEL V. CRISTALLI
Nevada Bar No. 6266
Attorney for Bautista
MOTION TO EXTEND THE DATE FOR
SELF-SURRENDER
(Expedited Treatment Request)
COMES NOW, Tiffany Bautista, Defendant herein, by and through her respective counsel Michael V. Cristalli, Esq., of Gordon Silver, and respectfully moves this Honorable Court to allow a brief extension of her self-surrender date.
This motion is based on the attached Memorandum of Points and Authorities and any evidence and/or argument that may be adduced should a hearing be required in this matter.
GORDON SILVER
____________________
MICHAEL V. CRISTALLI
Nevada Bar No. 006266
3960 Howard Hughes Pkwy., 9th Floor
Las Vegas, Nevada 89169
(702) 796-5555
Attorney for Bautista
MEMORANDUM OF POINTS AND AUTHORITIES
That the undersigned counsel and the Government have entered into several stipulations to extend Ms. Bautista self- surrender date for the purpose of testifying in several cases. Ms. Bautista was scheduled to testify in the matter of United States of America v. Michael Shomer, case number: 2:10-CR-493-JCM-VCF. Trial in this matter had been pushed out several times and was scheduled to go forward on March 25, 2013. However, the undersigned counsel learned for the Government that Mr. Shomer had missed his court date and absconded to Europe and as such, Ms. Bautista's testimony would no longer be needed.
Ms. Bautista is currently scheduled to self-surrender May 28, 2013, and would like to request an extension of her self-surrender date until after July 9, 2013. She would like an opportunity to attend her son's graduation and prepare him for his first day of school. In addition she would like to use this time to put her finances and personal affairs in order and make sure her son is taken care of while she serves her time.
Ms. Bautista has been compliant will all of this Court's requirements since her sentencing.
CONCLUSION
Ms. Bautisa has continued to be complaint with this Court's requirements and respectfully prays that this Honorable Court grant said motion to extend her self-surrender date.
GORDON SILVER
____________________
MICHAEL V. CRISTALLI
Nevada Bar No. 6266
3960 Howard Hughes Pkwy., 9th Floor
Las Vegas, Nevada 89169
(702) 796-5555
Attorney for Bautista
ORDER IT IS SO ORDERED that defendant's date to self-surrender is extended to Monday, July 15, 2013, at noon.
____________________
Lloyd D. George, Sr.U.S. District Judge