Opinion
2:19-cr-00154-RFB-VCF-2
01-10-2023
UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL HALPRIN, Defendant.
T. LOUIS PALAZZO, ESQUIRE Nevada Bar No. 4128 PALAZZO LAW FIRM A PROFESSIONAL LAW CORPORATION NATHAN F. GARRETT pro hac vice LUCINDA H. LUETKEMEYER pro hac vice GRAVES GARRETT LLC Attorneys for Defendant Michael Halprin
T. LOUIS PALAZZO, ESQUIRE Nevada Bar No. 4128
PALAZZO LAW FIRM
A PROFESSIONAL LAW CORPORATION
NATHAN F. GARRETT
pro hac vice
LUCINDA H. LUETKEMEYER
pro hac vice
GRAVES GARRETT LLC
Attorneys for Defendant Michael Halprin
JOINT STIPLUATION TO CONTINUE DEFENDANT HALPRIN'S SENTENCING HEARING SCHEDULED FOR JANUARY 19, 2023
THE HONORABLE RICHARD F. BOULARE, UNITED STATES DISTRICT JUDGE.
IT IS HEREBY STIPULATED AND AGREED by and between JASON FRIERSON, United States Attorney, District of Nevada, and JACOB OPERSKALSKI, Assistant United States Attorney, representing the United States of America, LOUIS PALAZZO, NATHAN GARRETT, and LUCINDA LUETKEMEYER, representing Defendant Michael Halprin, that the sentencing hearing scheduled for January 19, 2023, at 9:00 a.m., in the above-captioned matter, be vacated and continued to a date and time to be set by this Honorable Court but no sooner than one hundred fifty (150) days.
This stipulation is entered into for the following reasons:
1. Sentencing in this matter is currently scheduled for January 19, 2023, at 9:00 a.m.
2. Defense counsel needs additional time to investigate issues relevant to sentencing and prepare for sentencing.
3. Mr. Halprin has appeared in this case, and is not in custody and, along with the government, agrees to this continuance.
4. The additional time requested herein is not sought for purposes of delay and the denial of this request for a continuance could result in a miscarriage of justice.
5. Federal Rule of Criminal Procedure 32(b)(2) permits this Court to continue a sentencing hearing for good cause. Good cause exists in this case.
6. Counsel for Defendant Michael Halprin and the government agree a continuance of the sentencing hearing is in the best interests of justice.
7. For all the above-stated reasons, the ends of justice would be best served by the continuance of the sentencing hearing.
This is the second request for a continuance of the sentencing hearing.
DATED: January 9, 2023.
PALAZZO LAW FIRM
A PROFESSIONAL LAW
CORPORATION
By Nathan F. Garrett
T. Louis Palazzo, Esquire
GRAVES GARRETT, LLC
Nathan F. Garrett, pro hac vice
Lucinda H. Luetkemeyer, pro hac vice Counsel for Defendant Michael Halprin
JASON FRIERSON
United States Attorney
By Jacob Operskalski
Jacob Operskalski
Assistant United States Attorney
JOINT STIPLUATION TO CONTINUE DEFENDANT HALPRIN'S SENTENCING HEARING SCHEDULED FOR JANUARY 19,2023
Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:
1. Sentencing in this matter is currently scheduled for January 19, 2023 at 9:00 a.m.
2. Defense counsel needs additional time to investigate issues relevant to sentencing and prepare for sentencing.
3. Mr. Halprin has appeared in this case, and is not in custody and, along with the government, agrees to this continuance.
4. The additional time requested herein is not sought for purposes of delay and the denial of this request for a continuance could result in a miscarriage of justice.
5. Federal Rule of Criminal Procedure 32(b)(2) permits this Court to continue a sentencing hearing for good cause. Good cause exists in this case.
For all of the above-stated reasons, the ends of justice would best be served by an order vacating the current sentencing hearing date and continuing the sentencing hearing date no sooner than one hundred fifty (150) days.
ORDER
IT IS HEREBY ORDERED that the sentencing hearing currently scheduled for January 19, 2023, at the hour of 9:00 a.m., be vacated and continued to June 22, 2023, at the hour of 9:00 am/pm.