The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
BENJAMIN B. WAGNER United States Attorney TODD D. LERAS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2918
STIPULATION AND [PROPOSED] ORDER CONTINUING SENTENCING HEARING AND MODIFYING PRE-SENTENCE REPORT DISCLOSURE SCHEDULE
DATE: October 7, 2011 TIME: 9:00 a.m.
COURT: Hon. Garland E. Burrell, Jr.
IT IS HEREBY STIPULATED by and between Plaintiff United States of America and Attorney Hugh Anthony Levine, Counsel for Defendant Michael Dennis, that the sentencing hearing date of October 7, 2011, be continued to December 2, 2011, at 9:00 a.m.
The request to continue the sentencing hearing is made on the ground that the parties require additional time to develop and present pertinent information bearing upon defendant's sentence. Defendant has previously entered a guilty plea. Continuing the sentencing hearing therefore has no bearing on time considerations under the Speedy Trial Act. The parties have consulted with the assigned United States Probation Officer to confirm her availability on the requested date.
The parties agree to the following schedule for the disclosure of pre-sentence report, which has been approved by the assigned probation officer:
Proposed PSR to Counsel: Completed Counsel's Written Objections to Probation Completed Pre-Sentence Report Filed with Court November 3 Motions for Correction to PSR November 10 Reply or Statement of Non-Opposition November 18 Hugh Anthony Levine agrees to this request and has authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on his behalf.
1. The sentencing hearing set for October 7, 2011, is continued to December 2, 2011, at 9:00 a.m.
2. The schedule for disclosure of the pre-sentence report is modified as set forth in the stipulation of the parties.
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