Opinion
2:22-cr-00147-APG-EJY
12-21-2022
UNITED STATES OF AMERICA, Plaintiff, v. RAUL GIL, Defendant.
COOK & KELESIS, LTD. GEORGE P. KELESIS, ESQ. Nevada Bar No. 000069 Counsel for Defendant Gil Sunethra Muralidhara Nevada Bar No. 013549 Counsel for Defendant Gil JASON M. FRIERSON UNITED STATES ATTORNEY Eric C. Schmale Assistant United States Attorney THOMAS W. FLYNN JACOB M. GREEN Trial Attorney
COOK & KELESIS, LTD.
GEORGE P. KELESIS, ESQ.
Nevada Bar No. 000069
Counsel for Defendant Gil
Sunethra Muralidhara
Nevada Bar No. 013549
Counsel for Defendant Gil
JASON M. FRIERSON UNITED STATES ATTORNEY
Eric C. Schmale
Assistant United States Attorney
THOMAS W. FLYNN
JACOB M. GREEN
Trial Attorney
STIPULATION TO CONTINUE SENTENCING (SECOND REQUEST)
ANDREW P. GORDON, UNITED STATES DISTRICT JUDGE
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, United States Attorney, Eric C. Schmale, Assistant United States Attorney, Thomas W. Flynn and Jacob M. Green, Trial Attorneys, as counsel for the United States of America, and George P. Kelesis and Sunethra Muralidhara, as counsel for the defendant, Raul Gil, that the sentencing in the above-captioned matter, currently scheduled for February 2, 2023 at 9:00 AM, be vacated and continued to April 5, 2023 or another date convenient to this Court.
The parties have communicated with the Court's Clerk, who advised that the April 5th date is available on this Court's calendar. If this date is still convenient to the Court, the parties request that sentencing be rescheduled on this day, after 11:00 AM (PST), as defense counsel has sentencing in another matter currently set before Judge Navarro at 10:00 AM. Alternatively, the parties are available any day from April 18, 2023 to April 22, 2023, preferably in the afternoon.
This Stipulation is entered into for the following reasons:
1. Defendant is out of custody and does not object to the continuance.
2. Counsel for the Government will be out of the district and not available on the current date set for sentencing.
3. The parties need additional time to determine their positions regarding sentencing, gather and prepare support for their positions, file sentencing memoranda, and prepare for argument.
4. The parties agree to the continuance.
5. The additional time requested by this Stipulation is made in good faith and not for pinposes of delay.
This is the second request for continuation of the sentencing hearing.
ORDER CONTINUING SENTENCING HEARING
Based on the Stipulation of counsel and for good cause appearing, the Court hereby continues the sentencing of Defendant Raul Gil in this matter. The ends of justice served by granting said continuance outweigh the best interest of the public and the Defendant in a speedy sentencing because:
1. Defendant is out of custody and does not object to the continuance.
2. Counsel for the Government will be out of the district and not available on the current date set for sentencing.
3. The parties need additional time to prepare for sentencing effectively and thoroughly.
4. The parties agree to the continuance.
IT IS THEREFORE ORDERED that the sentencing in the above-captioned matter, currently scheduled for February 2, 2023 at 9:00 AM is vacated and continued to the April 5, 2023 at 1:30 p.m. in Courtroom 6C.