Filed: May 16, 2016
Latest Update: May 16, 2016
Summary: STIPULATION TO CONTINUE SENTENCING HEARING AND PROPOSED ORDER JAMES C. MAHAN , District Judge . Defendant Jacqueline Gentle, by and through her attorney of record, Kathleen Bliss, Esq., of the law firm Kathleen Bliss Law PLLC; and Assistant United States Attorney J. Gregory Damm, hereby stipulate and request that the Court vacate the sentencing hearing in this matter currently set for June 2, 2016, and continue it until June 29, 2016, or a time thereafter most convenient for the Court. In
Summary: STIPULATION TO CONTINUE SENTENCING HEARING AND PROPOSED ORDER JAMES C. MAHAN , District Judge . Defendant Jacqueline Gentle, by and through her attorney of record, Kathleen Bliss, Esq., of the law firm Kathleen Bliss Law PLLC; and Assistant United States Attorney J. Gregory Damm, hereby stipulate and request that the Court vacate the sentencing hearing in this matter currently set for June 2, 2016, and continue it until June 29, 2016, or a time thereafter most convenient for the Court. In s..
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STIPULATION TO CONTINUE SENTENCING HEARING AND PROPOSED ORDER
JAMES C. MAHAN, District Judge.
Defendant Jacqueline Gentle, by and through her attorney of record, Kathleen Bliss, Esq., of the law firm Kathleen Bliss Law PLLC; and Assistant United States Attorney J. Gregory Damm, hereby stipulate and request that the Court vacate the sentencing hearing in this matter currently set for June 2, 2016, and continue it until June 29, 2016, or a time thereafter most convenient for the Court.
In support of this Stipulation, the parties show the Court as follows:
1. The additional time requested by this Stipulation to Continue Sentencing Hearing is reasonable pursuant to Fed.R.Crim.P. 32(b)(2), which states that the "court may, for good cause, change any time limits prescribed [for sentencing] in this rule."
2. The parties are requesting additional time to allow court-approved mitigation expert Dr. John Paglini, Ph.D. to interview Ms. Gentle in preparation of her sentencing.
3. Several legitimate mitigation factors have been identified that may have affected Ms. Gentle's role in the offense.
4. Dr. Paglini has informed counsel for Ms. Gentle that his interview of Ms. Gentle will require two (2) visits; one on May 27, 2016 and another on June 3, 2016. Ms. Gentle is currently being detained at the Nevada Southern Detention Center in Pahrump.
5. Dr. Paglini has informed counsel for Ms. Gentle that his final report will be completed by June 21, 2016.
6. Defense counsel for JACQUELINE GENTLE has spoken to her client, who is currently in custody, and she has no objection to the continuance.
7. Based on Dr. Paglini's schedule, counsel for Ms. Gentle and the Government and hereby stipulate and agree to vacate Ms. Gentle's June 2, 2016, sentencing date and continue it until June 29, 2016, or a time thereafter most convenient to the Court.
8. The additional time requested herein is not sought for purposes of delay.
9. Denial of this request for a continuance would deny counsel for the defendants sufficient time, to effectively and thoroughly prepare for sentencing. Accordingly, a denial of this request for continuance could result in a miscarriage of justice.
This is the second stipulation to continue filed herein.
ORDER
The Court, having reviewed the Stipulation to Continue Sentencing, finds good cause to GRANT the parties' request.
IT IS HEREBY ORDERED that the defendant's sentencing hearing currently scheduled for June 2, 2016, is hereby VACATED.
IT IS FURTHER ORDERED that defendant's sentencing hearing is reset for JUNE 29, 2016, at 10:30 a.m.
