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`RENE L. VALLADARES
`Federal Public Defender
`State Bar No. 11479
`JOY CHEN
`Assistant Federal Public Defender
`411 E. Bonneville, Ste. 250
`Las Vegas, Nevada 89101
`(702) 388-6577/Phone
`(702) 388-6261/Fax
`Joy_Chen@fd.org
`
`Attorney for Asharon Bravo
`
`
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`
`UNITED STATES OF AMERICA,
`
`
`
`Plaintiff,
`
`
`v.
`
`ASHARON BRAVO,
`
`
`
`Defendant.
`
`
`
` Case No. 2:14-cr-00103-GMN-VCF-1
`
`STIPULATION TO CONTINUE
`REVOCATION HEARING
`(First Request)
`
`
`IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson,
`United States Attorney, and Allison Reese, Assistant United States Attorney, counsel for the
`United States of America, and Rene L. Valladares, Federal Public Defender, and Joy Chen,
`Assistant Federal Public Defender, counsel for Asharon Bravo, that the Revocation Hearing
`currently scheduled on October 27, 2023, be vacated and continued to a date and time
`convenient to the Court, but no sooner than one hundred and twenty (120) days.
`This Stipulation is entered into for the following reasons:
`The parties have reached a tentative resolution of this matter. The parties seek
`1.
`to continue the matter by four months to allow Ms. Bravo to come into compliance with the
`terms of her supervised release. If she is able to do so and does not sustain any additional
`
`
`
`Case 2:14-cr-00103-GMN-VCF Document 403 Filed 10/24/23 Page 2 of 3
`
`
`
`violations, the Government and the United States Probation Office will recommend dismissal
`of the instant petition to revoke supervised release.
`Ms. Bravo is out of custody and does not oppose the continuance.
`2.
`3.
`The parties agree to the continuance.
`This is the first request for a continuance of the revocation hearing.
`DATED this 19th day of October, 2023.
`
`
`
`
`
`
`RENE L. VALLADARES
`Federal Public Defender
`
`
`
`By /s/ Joy Chen
`JOY CHEN
`Assistant Federal Public Defender
`
`
`
`JASON M. FRIERSON
`United States Attorney
`
`
`
`By /s/ Allison Reese
`ALLISON REESE
`Assistant United States Attorney
`
`
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`Case 2:14-cr-00103-GMN-VCF Document 403 Filed 10/24/23 Page 3 of 3
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`UNITED STATES OF AMERICA,
`Plaintiff,
`
`Case No. 2:14-cr-00103-GMN-VCF-1
`
`ORDER
`
`v.
`ASHARON BRAVO,
`Defendant.
`
`IT IS THEREFORE ORDERED that the revocation hearing currently scheduled for
`February 27, 2024
`Friday, October 27, 2023 at 10:00 a.m., be vacated and continued to ________________ at the
`hour of 9:00 a.m.
`DATED this ___ day of October, 2023.
`
`UNITED STATES DISTRICT JUDGE
`
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