Opinion
2:19-cr-00129-JCM-DJA-2
01-19-2022
UNITED STATES OF AMERICA, Plaintiff, v. RAFAEL MARTINEZ, Defendant.
RENE L. VALLADARES Federal Public Defender Nevada State Bar No. 11479 NAVID AFSHAR Assistant Federal Public Defender Attorney for Rafael Martinez CHRISTOPHER CHIOU Acting United States Attorney JIM W. FANG Assistant United States Attorney
RENE L. VALLADARES
Federal Public Defender
Nevada State Bar No. 11479
NAVID AFSHAR
Assistant Federal Public Defender
Attorney for Rafael Martinez
CHRISTOPHER CHIOU
Acting United States Attorney
JIM W. FANG
Assistant United States Attorney
STIPULATION TO CONTINUE REVOCATION HEARING
IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou, Acting United States Attorney, and Jim W. Fang, 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 Rafael Martinez, that the Revocation Hearing currently scheduled on January 21, 2022, be vacated and continued to a date and time convenient to the Court, but no sooner than twenty-one (21) days.
This Stipulation is entered into for the following reasons:
1. Counsel is unable to communicate with client due to long delays in securing appointment at jail.
2. Matter is close to resolving. Counsel needs to review with client.
3. Defendant is incarcerated and does not object to a continuance. 1
4. Additionally, denial of this request for continuance could result in a miscarriage of justice.
This is the first request for continuance filed herein. 2
ORDER
Based on the Stipulation of counsel and good cause appearing, IT IS THEREFORE ORDERED that the Revocation Hearing currently scheduled on January 21, 2022 at the hour of 10:30 a.m., be vacated and continued to March 4, 2022 at the hour of 10:30 a.m. 3