Opinion
2:16-CR-0322-KJD-CWH
11-02-2022
UNITED STATES OF AMERICA, Plaintiff, v. MARY ELLEN MARTINEZ, Defendant.
RENE L. VALLADARES Federal Public Defender JASON M. FRIERSON United States Attorney JACQUELYN N. Assistant Federal Public Defender WITT JIM W. FANG Assistant United States Attorney
RENE L. VALLADARES Federal Public Defender
JASON M. FRIERSON United States Attorney
JACQUELYN N. Assistant Federal Public Defender
WITT JIM W. FANG Assistant United States Attorney
STIPULATION TO CONTINUE REVOCATION HEARING (Fourth Request)
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, 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 Jacquelyn N. Witt, Assistant Federal Public Defender, counsel for Mary Ellen Martinez, that the Revocation Hearing currently scheduled on November 4, 2022 at 11:30 am, be vacated and continued to a date and time convenient to the Court, but no sooner than thirty (30) days.
This Stipulation is entered into for the following reasons:
1. Since the last stipulation was filed, defense counsel has conferred with Ms. Martinez and acquired mitigation documents in preparation for the revocation hearing.
2. Defense counsel has requested additional documentation and needs more time to acquire and review the requested documents.
3. Defense counsel needs additional time to discuss this matter with Ms. Martinez, and prepare for the revocation hearing.
4. Ms. Martinez is in custody and agrees with the need to continue the revocation hearing.
5. The parties agree to the continuance.
This is the fourth request for a continuance of the revocation hearing.
IT IS THEREFORE ORDERED that the revocation hearing currently scheduled for Thursday, November 4, 2022 at 11:30 a.m., be vacated and continued to December 7, 2022 at the hour of 9:30 a.m.; or to a time and date convenient to the court in courtroom 4A.