The opinion of the court was delivered by: The Honorable, Ronald M. Whyte
Stipulation and 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 April 15, 2011 to May 31, 2011.
As reasons therefore, the parties submit the following:
1. On January 10, 2011, this court sentenced the defendant to a period of 48 months of incarceration. Currently, he is scheduled to self report on April 15, 2011 to serve his sentence
2. The defendant has a severely handicapped 20 year old daughter who essentially functions like a one year old.
3. In order for the Daly family to remain intact, without his daughter forced into some alternative living situation, the Dalys are in the process of selling their family home and moving into a new, smaller home which they have previously acquired.
4. The closing for sale of the Daly home is tentatively scheduled for April 23, 2011.
5. Mr. Day has informed me that this extension is necessary in order to assure that the closing takes place as scheduled or soon thereafter and because he needs to assist his family in moving from their current home into their new home and because he is retrofitting the new home with some special handicap accessible equipment which is on order but has not arrived yet.
6. 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: April 5, 2011
It is hereby ordered that the time for the defendant Michael A. Daly to self report to serve his sentence is extended from ...