The opinion of the court was delivered by: The Honorable Susan Illston United States District Judge
STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATES
Before the Honorable Susan Illston WHEREAS the hearing of Defendant Tammy Thomas's Renewed Motion for Judgment of Acquittal and Motion for New Trial and Arrest of Judgment have been preserved and are scheduled to be heard on July 25, 2008;
WHEREAS the sentencing in this matter is currently scheduled for July 25, 2008;
WHEREAS the jury returned its verdict on April 4, 2008;
WHEREAS counsel for the defendant had been continuously in trial preparation from April 15 through May 14, 2008 for a confidential arbitration pending before JAMS;
WHEREAS counsel for defendant has significant other matters pending, including court service obligations to this Court, to the Central District, and to the Ninth Circuit Court of Appeals pursuant to the Criminal Justice Act in June and July 2008;
WHEREAS counsel for defendant requires additional time to prepare this matter for sentencing and to prepare post trial motions;
WHEREAS, counsel for the United States agrees that it will not be prejudiced by a short continuance of the July 25 hearing date;
IT IS HEREBY STIPULATED AND AGREED that the matters currently scheduled to be heard on July 25, 2008 are continued to September 5, 2008 to be heard on the Court's 11:00 a.m. calendar;
IT IS FURTHER STIPULATED AND AGREED that the deadlines applicable to the preparation and presentation of the Proposed and Final Probation Report to be presented by the United States Probation Office are hereby extended and should be calculated as if the Original Sentencing Date shall take place on September 5, 2008.
STIPULATED AND AGREED TO:
BASED ON THE FOREGOING STIPULATION AND FOR GOOD CAUSE SHOWN, the Court hereby continues the hearing of the sentencing and hearings set forth in the above Stipulation. Defendants' Motions for Acquittal and for New Trial/Arrest of Judgment shall be considered timely if filed on or before August 8, 2008; the Government shall respond on August 22; and Defendant shall reply on or before August 29, 2008;
IT IS FURTHER ORDERED that the deadlines applicable to the preparation and presentation of the Proposed and Final Probation Report to be presented by the United States Probation Office are hereby extended and should be calculated as if the ...