The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
Timothy E. Warriner Attorney at Law 660 J St., Suite 390 Sacramento, CA 95814 (916) 443-7141 Attorney for Defendant, JEFFREY CONNER
STIPULATION AND [PROPOSED] ORDER FOR PRE-PLEA PRESENTENCE INVESTIGATION REPORT, FOR CONTINUANCE OF STATUS CONFERENCE, AND FOR EXCLUSION OF TIME
Counsel for the government, Jason Hitt, and counsel for defendant Jeffrey Conner, Timothy E. Warriner, hereby jointly request that the court order the United States Probation Department to complete a Pre-Plea Presentence Investigation Report. The parties request a Pre-Plea Presentence Investigation Report in order to assist in the resolution of this case by way of plea agreement, and it is believed that such report will resolve issues concerning application of the Sentencing Guidelines, including issues relating to Mr. Conner's criminal history.
It is further requested and stipulated that the Pre-Plea Presentence Investigation Report be distributed only to the parties on or before August 26, 2011, and that it not be disclosed to the court until after any guilty plea is entered, or in the event the defendant is found guilty after trial.
The parties request that the status conference now set for July 8, 2011 be continued to August 26, 2011, and that time be excluded to August 26, 2011 for the continued preparation of counsel (Local Code T 4; 18 U.S.C. § 3161(h)(7)(B)(iv)).
Pursuant to the stipulation of the parties, it is hereby ordered that the United States Probation Department prepare a Pre-Plea Presentence Investigation Report. The report is to be disclosed to the parties not later than August 26, 2011. The report is not at this time to be filed with the court.
It is further ordered that the status conference set for July 8, 2011 be continued to August 26, 2011 at 9:00 a.m., and that time continue to be excluded to August 26, 2011 for preparation of counsel (Local Code T 4; 18 U.S.C. § 3161(h)(7)(B)(iv)).
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