IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 11, 2011
UNITED STATES OF AMERICA
OWEN L. CHARLES,
The opinion of the court was delivered by: Edward J. Garcia U.S. District Judge
J TONEY SB# 43143 Box 1515 Woodland CA 95776 (530) 666-1908 Attorney for Defendant
ADDITIONAL SENTENCE MEMO AND
MOTION TO CONTINUE SENTENCING
Date: June 10, 2011
Before: Hon. Edward J. Garcia
This case is now set for sentencing on May 13, 2011. Defendant Charles now moves for a continuance until June 10, 2011 for the following reasons:
The Government in its sentencing memorandum points out that several Defense arguments are not corroborated. It should be noted that the Government's assertions that many items represent taxable income are assumptions as well. In order to properly corroborate the Defense claims, additional time will be needed to acquire supporting documents. For this reason, the Defense request that the case be continued to June 10, 2011 and that an evidentiary hearing be held on that date or later to fully litigate the proper amount of loss.
In addition, an explanation of certain items that are properly considered transfers and therefore not taxable have been located and are attached to this motion.
DECLARATION OF COUNSEL I , J Toney, declare under penalty of perjury that the above facts are true and correct. Dated May 10, 2011 at Woodland CA /s/ J TONEY J Toney
Good Cause appearing, the motion of the Defendant to continue sentencing until June 10, 2011 is GRANTED.
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