Opinion
2:20-cr-00319-JCM-EJY
04-08-2022
UNITED STATES OF AMERICA, Plaintiff, v. RUBEN MARTIN COVARRUBIAS-GUERRA, Defendant.
RENE L. VALLADARES Federal Public Defender State Bar No. 11479 NAVID AFSHAR Assistant Federal Public Defender Attorney for Ruben Martin Covarrubias-Guerra CHRISTOPHER CHIOU Acting United States Attorney EDWARD G. VERONDA Assistant United States Attorney
RENE L. VALLADARES
Federal Public Defender
State Bar No. 11479
NAVID AFSHAR
Assistant Federal Public Defender
Attorney for Ruben Martin Covarrubias-Guerra
CHRISTOPHER CHIOU
Acting United States Attorney
EDWARD G. VERONDA
Assistant United States Attorney
STIPULATION TO CONTINUE SENTENCING HEARING
(SECOND REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou, Acting United States Attorney, and Edward G. Veronda, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Navid Afshar, Assistant Federal Public Defender, counsel for Ruben Martin Covarrubias-Guerra, that the Sentencing Hearing currently scheduled on April 15, 2022, be vacated and continued to a date and time convenient to the Court, but no sooner than ninety (90) days.
This Stipulation is entered into for the following reasons:
1. Mr. Covarrubias's family has sent in numerous letters that require translation from Spanish to English and more time is needed to translate as additional letters are expected.
2. Additionally, counsel is still weighing whether to employ an expert for Mr. Covarrubias's sentencing hearing.
3. To coordinate schedules with both parties, we ask for no less than 60 days but preferably 90 due to upcoming trials, and other matters that conflict with counsel's respective schedules.
4. The defendant is in custody and agrees with the need for the continuance.
5. The parties agree to the continuance.
This is the second request for a continuance of the sentencing hearing.
ORDER
IT IS THEREFORE ORDERED that the sentencing hearing currently scheduled for Friday, April 15, 2022 at 10:00 a.m., be vacated and continued to July 15, 2022, at 10:00 a.m.