UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
July 12, 2010
UNITED STATES, PLAINTIFF
MICHAEL A. DALY, DEFENDANT
The opinion of the court was delivered by: Hon. Ronald M. Whyte U.S. District Court Judge
Stipulation And Order To Continue Sentencing
Now come the parties in this case and stipulate and agree to continue sentencing from July 19, 2010, to September 13, 2010 or to a date thereafter convenient to the Court.
As reasons therefore, counsel submits the following:
1. Counsel for the defendant has consulted with AUSA Richard Cheng, who assents to this Motion.
2. Counsel for the defendant has consulted with US Probation Officer Benjamin Flores, who assents to this Motion.
3. Counsel for the defendant and the United States are actively involved in negotiating the applicability of various sentencing factors in this case and are not prepared to make final recommendations to the Court.
4. The defendant has made substantial restitution payments to the victim in this case and expects to make complete restitution payments prior to September 13, 2010, but has not completed his restitution obligations as of this date.
5. Continuing sentencing in this case is in the best interest of justice.
Wherefore, the defendant Michael A. Daly requests that this Court continue sentencing as requested herein.
Respectfully Submitted, By the Defendant's Attorney,
Liam D. Scully (Pro hac vice) Pavlos Vitali & Scully 142 Main Street, #406 Brockton, MA 02301 (508) 894-0050
Richard Cheng United States Attorney's Office
So Ordered: July 14, 2010
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