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United States v. Michael A. Daly

March 14, 2011

UNITED STATES,
PLAINTIFF
v.
MICHAEL A. DALY,
DEFENDANT



The opinion of the court was delivered by: The Honorable, Ronald M. Whyte

Liam D. Scully (Pro hac vice) (BBO#639234) 101 Summer Street Fourth Floor Boston, MA 02110 (617) 307-5056 Douglas Louison (Pro hac vice) (BBO#545191) Bradford N. Louison (Pro hac vice) (BBO#305755) David E. Condon (Pro hac vice) (BBO#642741)

*E-FILED - 3/14/11*

Stipulation and Proposed Order To Extend Time for The Defendant Michael Daly to Self Report To Serve His Sentence

Now come the parties in this case and stipulate and agree that this Court should extend the date scheduled for the defendant Michael Daly to self report to serve his sentence from March 15, 2011 to April 15, 2011.

As reasons therefore, the parties submit the following:

1. Mr. Daly was supposed to receive two weeks notice as to where he would self report.

2. He did not, however, receive notice of where to self report until March 10, 2011, just five days prior to his self reporting date of March 15, 2011.

3. Mr. Day has informed his counsel that this requested extension is necessary because he has several important meetings for extended care for his daughter, Caroline Daly, set up for next week and he has informed counsel that "it is imperative that we do not leave his severely handicapped daughter at risk."

4. Assistant United States Attorney Richard Cheng concurs in this Stipulation and Proposed Order.

Wherefore, the parties request that the Court adopt the proposed order set forth below.

Respectfully Submitted, By the Defendant's Attorney,

/s/Liam Scully Liam D. Scully (Pro hac vice) 101 Summer Street Fourth Floor Boston, MA 02110 (617) 307-5056

Dated: March ...


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