SIXTH STIPULATION TO CONTINUE SENTENCING

ANDREW P. GORDON, District Judge.

It is hereby stipulated and agreed between the United States of America, by and through Nicholas A. Trutanich, United States Attorney, and Daniel J. Cowhig, Assistant United States Attorney, and Adam M. Solinger, Esq., Las Vegas Defense Group, counsel for defendant Jessica Yvette Figueroa, that the sentencing hearing set for Tuesday, April 16, 2019 at 2:00 p.m. in Courtroom 6C before the Honorable Andrew P. Gordon be vacated and continued to a date and time convenient to the Court but no earlier than 60 days hence.

This stipulation is entered into for the following reasons:

For these reasons, the ends of justice would best be served by a continuance of the sentencing hearing to a date and time convenient to the Court but no earlier than 60 days hence.

A proposed order is attached.

PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

Based on the pending stipulation of counsel, and good cause appearing therefore, the Court finds that:

1. This is a joint request by counsel for the United States and for the defendant;

2. The additional time requested by this stipulation is reasonable pursuant to Federal Rule of Criminal Procedure 32(b)(2) which allows that "the Court may, for good cause, change any limits prescribed in this rule;"

3. Both counsel request this additional time to allow adequate time to research sentencing issues and prepare for the sentencing hearing;

4. Defendant Figueroa is at liberty on bond and consents to the continuance;

5. The United States Probation Office supervising defendant Figueroa has not reported any significant violation of the bond conditions;

6. This is the sixth such request for continuance.

Conclusions of Law

The ends of justice would be served by granting a continuance of the sentencing hearing. Were the continuance not granted, it would likely result in a miscarriage of justice, deny the parties sufficient time to effectively and thoroughly prepare for sentencing, taking into account the exercise of due diligence.

ORDER

IT IS HEREBY ORDERED, based upon the stipulation of the parties and the record in this case and for good cause shown, that the sentencing hearing currently scheduled for Tuesday, April 16, 2019 at 2:00 p.m. is continued to August 8, 2019 at 10:00 a. m. in Courtroom 6C.

IT IS SO ORDERED.