STIPULATION AND [PROPOSED] ORDER CONTINING SENTENCING HEARING AND SETTING SCHEDULE
It is hereby stipulated and agreed to between the United States of America through Jill Thomas, Assistant United States Attorney, and defendant, DANIEL HERNANDEZ, by and through his counsel, Lindsay Anne Weston, that the sentencing hearing in this matter currently scheduled for September 10, 2010, at 9:00 a.m. be continued to Oct. 22, 2010, at 9:00 a.m. It is requested that the Court adopt the following schedule for disclosure of and objections to the pre-sentence report.
Written objections to draft PSR: Sept. 24, 2010
Filing of final PSR: Oct. 1, 2010
Motion for correction of PSR: Oct. 8, 2010
Reply or statement of no-opposition: Oct. 15, 2010
The basis for this continuance, which is at the request of the defense, is to allow the defense sufficient time to meet with Mr. Hernandez, who is located at Butte Co. Jail, to review the draft PSR, which has already been disclosed, and to prepare objections, corrections or additions.
LINDSAY ANNE WESTON Attorney for Defendant DANIEL HERNANDEZ
BENJAMIN WAGNER United States Attorney
Lindsay Weston for Jill Thomas
Assistant United States Attorney Per e-mail ...