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United States of America v. Benjamin Santos Castro

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


October 7, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
BENJAMIN SANTOS CASTRO,
DEFENDANT.

STIPULATION AND [PROPOSED] ORDER MODIFYING PRE-SENTENCE REPORT DISCLOSURE SCHEDULE FOR DEFENDANT BENJAMIN SANTOS CASTRO

Stipulation

The parties, through undersigned counsel, stipulate that, as to defendant Benjamin Santos Castro, the disclosure schedule for the presentence report, and objections thereto, may be modified as detailed below.

Due to the complexities of this case, the proposed pre-sentence report was not disclosed by the Probation Department on the date originally set. Moreover, due to the volume of discovery, and number of issues, the parties will require more time to prepare objections than is ordinarily provided in a pre-sentence report disclosure and briefing schedule.

As such, the parties agree to the following schedule for the disclosure of the pre-sentence report and objections:

Proposed PSR to Counsel: Completed Counsel's Written Obj's to Probation: October 24, 2011 Presentence Report Filed With Court: November 7, 2011 Motion for Corrections to PSR: November 21, 2011 Reply or Statement of Non-Opposition: November 28, 2011 Evidentiary Hearing (already set/no change): December 6, 2001 The prosecutor has authorized defense counsel to sign this stipulation on his behalf.

DATED: October 7, 2011 BENJAMIN WAGNER United States Attorney by /s/ Scott Cameron, for William Wong Assistant U.S. Attorney DATED: October 7, 2011 by /s/ Scott N. Cameron Scott N. Cameron Counsel for BENJAMIN SANTOS CASTRO

Order

Good cause appearing,

The schedule for the disclosure of the pre-sentence report, and objections thereto, is modified as set forth in the above-stated stipulation.

IT IS SO ORDERED.

20111007

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