STIPULATION TO CONTINUE SENTENCING DATE (Second Request)

JENNIFER A. DORSEY, District Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Daniel Bogden, United States Attorney, and Susan Cushman, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and RAQUEL LAZO, Assistant Federal Public Defender, counsel for THOMAS KENNISTON, that the sentencing and disposition currently scheduled for Monday, June 29, 2015 at the hour of 10:00 a.m., be vacated and set to a date and time convenient to this Court but no earlier than sixty (60) days.

This Stipulation is entered into for the following reasons:

1. Mr. Kenniston has additional questions regarding the presentence investigation report. He resides in San Diego, California. Defense counsel plans on traveling to California and visiting him during the week of June 15, 2015.

2. The plea agreement allows Mr. Kenniston to seek a non-custodial sentence. Additional time is needed to complete the sentencing memorandum in this case.

3. Mr. Kenniston is asking for additional time to gather enough money for airfare and hotel expenses related to his travel from San Diego to Las Vegas for the hearing. He recently suffered some financial hardships and could use the additional time to save for such expenses.

4. Finally, defense counsel will be in trial in United States v. Warras, District Court Case No. 2:13-cr-439-LDG-VCF. The trial is expected to last approximately two (2) weeks. As such, defense counsel requests the hearing be continued until the end of August 2015.

5. The defendant is not incarcerated and agrees to the continuance in this matter.

6. This is the second stipulation to continue filed herein.

ORDER

Based on the pending Stipulation of counsel, and good cause appearing,

IT IS THEREFORE ORDERED that the sentencing hearing currently scheduled for Monday,

June 29, 2015 at the hour of 10:00 a.m., be vacated and continued to Wednesday, September, 9, 2015, at 10:00 a.m.