The opinion of the court was delivered by: Honorable Maxine M. Chesney
STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING
Date: July 16, 2008 Time: 2:30 p.m.
Court: The Honorable Maxine M. Chesney
Undersigned counsel stipulate as follows:
1. Sentencing in this matter is currently set for July 16, 2008, at 2:30 p.m.;
2. Defense counsel recently received several documents that she had requested and had asked her client to request from medical facilities, family friends and relatives. These documents include letters of support on behalf of Mr. Crayton;
letters explaining family circumstances leading to the instant offense, and medical records of Mr. Crayton's wife, Linda Crayton, which are relevant to the time period charged in the indictment;
3. These letters and medical records have been coming in over the last few weeks.
Defense counsel was not able to deliver a complete package of objections/ supplemental information for the Presentence Report to the Probation Officer until Friday, June 27, 2008, as these documents were still arriving over the week of June 23, 2008. The package delivered to the Probation Officer was voluminous, and contains three different sets of medical records and numerous letters of support. To ensure that the Probation Officer can adequately incorporate this material into the Final Presentence Report, a continuance is requested by defense counsel;
4. Defense counsel also needs to finalize her loss assessment prior to sentencing.
This analysis requires defense counsel to scrutinize 676 service vouchers individually to determine whether the voucher was issued legitimately or non- legitimately. This analysis is taking a substantial amount of time;
5. Defense counsel requests a continuance of the sentencing for these purposes of either one or two weeks, at the Court's discretion;
6. Government counsel has no opposition to the request for a continuance of the sentencing date for these purposes;
7. Defense counsel has conferred with Courtroom Deputy Tracy Lucero about the date best suited to the Court for a ...