STIPULATION RE-SCHEDULING SENTENCING HEARING AND AMENDING SCHEDULE FOR DISCLOSURE OF PRE-SENTENCE REPORT AND FOR FILINGS OF OBJECTIONS TO THE PRE-SENTENCE REPORT AND ORDER THEREON
Defendant Alex Hernandez, through his attorney of record, David J. Cohen, Esq., and Assistant United States Attorney, Michael M. Beckwith, Esq., after due consultation with Senior United States Probation Officer Thomas H. Brown, jointly request an extension of time for the sentencing hearing in this matter and jointly request the following revised disclosure schedule for sentencing filings in this case:
1. The parties stipulate and agree that the sentencing hearing in this case should be continued from October 18, 2010 at 8:30 a.m. to January 10, 2011 at 8:30 a.m.
2. The parties further stipulate and agree that the sentencing filings in this case are to be made and due as follows:
a. Reply or Statement due on January 3, 2011.
b. Motion for Correction of the Pre-Sentence Report shall be filed with the Court and served on the Probation Officer and opposing counsel no later than December 27, 2010.
c. The Pre-Sentence Report shall be filed with the Court and disclosed to counsel no later than December 20, 2010.
d. Counsel's written informal objections to the Pre-Sentence Report shall be delivered to the Probation Officer and opposing counsel no later than December 13, 2010.
e. The Proposed Pre-Sentence Report shall be disclosed to counsel no later than November 29, 2010.
BENJAMIN B. WAGNER United States Attorney
MICHAEL M. BECKWITH Assistant U.S. Attorney Attorney for Plaintiff
DAVID J. COHEN Attorney for Defendant ...