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) Merrick, Louison & Costello, LLP 67 Batterymarch Street Boston, MA 02110 (617) 439-0305 Local Counsel: Benjamin W. Williams, Esq. (SBN# 230861) John Williams, Esq. (SBN # 43912) Manchester, Williams & Seibert 125 S. Market Street, Suite 1100 San Jose, CA 95113-2286 (408) 287-6193
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 May 31, 2011 to June 30, 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 May 31, 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 which was previously anticipated to happen on or about April 23, 2011 is now scheduled for June 9, 2011.
5. I have reviewed the purchase and sale agreement verifying this closing date and forwarded same to Assistant United States Attorney Richard Cheng for his review.
6. Assistant United States Attorney Richard Cheng concurs in this Stipulation and Proposed Order.
7. I believe that granting this extension to self report is in the best interests of justice because it will allow Mr. Daly to set up his wife and handicapped daughter in their new home where they will live while he serves his sentence.
Wherefore, the parties request that the Court adopt the proposed ...