Opinion
9699 2:19-cr-0133-APG-VCF
08-29-2022
UNITED STATES OF NEVADA, Plaintiff, v. MIRIAM ELIZABETH SUAREZ-CONTRERAS 1, aka “Ella” aka “Liz”, Defendant.
Richard Tanasi Melanee Smith Attorney for the UNITED STATES Richard E. Tanasi, Esq. Attorney for Defendant
Richard Tanasi Melanee Smith Attorney for the UNITED STATES
Richard E. Tanasi, Esq. Attorney for Defendant
STIPULATION AND ORDER TO CONTINUE SENTENCING HEARING (First Request)
IT IS HEREBY STIPULATED AND AGREED, Melanee Smith, Assistant United States Attorney, counsel for the United States of America, and; Richard E. Tanasi, Esq., counsel for Defendant Miriam Elizabeth Suarez- Contreras (1); that the Sentencing Hearing in the above-captioned matter, now scheduled for September 21, 2022 at the hour of 10:30 a.m., be vacated and continued to a time convenient for the Court after December 7, 2022.
Pursuant to General Order No. 2007-04, this Stipulation is entered into for the following reasons:
1. All defendants have not yet entered a guilty plea, which is a factor in Ms. Suarez's potential sentence in this case given the group plea contemplated in her guilty plea agreement.
2. Defense counsel needs more to prepare Presentence Report Objections, the sentencing memorandum, and for sentencing given the need to translate relevant communications from English to Spanish.
2. Defense Counsel is preparing for a trial likely to last from September 26, 2022 to November 4, 2022 in United States v. Castro, et al 2:19-cr-295-GMN-NJK .
2. Ms. Suarez is in custody and does not object to this continuance.
4. The additional time requested herein is not sought for purposes of delay.
4. Additionally, denial of this request for continuance could result in a miscarriage of justice.
WHEREFORE, the parties respectfully request that this Honorable Court accept the Stipulation and enter an Order as set forth below, continuing the sentencing hearing for date convenient to the Court, after December 7, 2022 .
ORDER ON STIPULATION
This matter coming before the Court on Stipulation to Continue Sentencing Hearing, the Court having considered the matter, and good cause showing, the Court accepts the Stipulation.
WHEREFORE, IT IS HEREBY ORDERED, that the Sentencing Hearing in the above-captioned matter, now scheduled for September 21, 2022 at the hour of 10:30 a.m., be vacated and continued to December 28, 2022, at 9:00 a.m. in Courtroom 6C.