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United States v. Crayton

May 28, 2008

UNITED STATES OF AMERICA, PLAINTIFF,
v.
LAWRENCE CRAYTON, DEFENDANT.



The opinion of the court was delivered by: The Honorable Maxine M. Chesney

STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING DATE

Date: June 11, 2008

Undersigned counsel stipulate as follows:

1. Sentencing in this matter is currently set for June 11, 2008, at 2:30 p.m.;

2. Mr. Crayton entered an open plea before this Court on March 5,2008. Defense counsel needs more time to review the documents associated with loss amount in this matter, which the Probation Department has set at $239,000. Government counsel submitted a spreadsheet to both defense counsel and the Probation Officer calculating loss. The government's loss amount is supported by over 2,000 documents associated with the false service vouchers issued by Mr. Crayton while he was employed at Amtrak. Defense counsel believes that some of these vouchers should not be included in the loss amount, and she needs more time to review the individual vouchers to make this determination;

3. Defense counsel also needs to finalize her loss assessment prior to filing a final objection letter with the Probation Department for the Presentence Report;

4. Defense counsel requests a continuance of the sentencing for these purposes;

5. Government counsel has no opposition to the request for a continuance of the sentencing date for these purpose;

6. Defense counsel has conferred with the Probation Officer assigned to this matter, Cris Carruba. Ms. Carruba is not available for Mr. Crayton's sentencing on any date in June. Given the July 4th holiday, the parties have agreed to request a sentencing date of July 16, 2008 at 2:30 p.m.;

7. USPO Cris Carruba has been contacted by defense counsel, and has no objection to a continuance of the sentencing date to July 16, 2008 at 2:30 p.m. She requests the Court to further order that the Final Presentence Report in this matter is not due until July 2, 2008, which will allow defense counsel sufficient time to submit final objections to the draft Presentence Report.

IT IS SO STIPULATED

Dated: May 27, 2008

CHRISTINA HUA Assistant United ...


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