STIPULATION AND [PROPOSED] ORDER CONTINUING THE JUDGMENT AND SENTENCING OF FERNANDO MORENO-) CAMACHO
The parties, through undersigned counsel, stipulate that the judgment and sentencing of defendant FERNANDO MORENO-CAMACHO, currently scheduled for September 17, 2012, may be continued to October 9, 2012, at 9:30 a.m., and the schedule for objections may be modified as set forth below.
The publication of final presentence report to the parties was delayed and defense counsel needs the additional time requested to prepare the formal objections. In addition, there appears to be a clerical error in the final presentence report, that once clarified, may eliminate the need for objections and litigation. The assigned Probation Officer is out of the office until September 10, 2012. Thus, the additional time is also requested so that defense counsel can confer with the Probation Officer to determine if there exists a clerical error, thus eliminating the need for objections.
Furthermore, the parties stipulate to the following schedule of disclosure/briefing schedule:
Proposed PSR Disclosed to Counsel: Completed Counsel's Written Objections to Probation: Completed Pre-Sentence Report Filed with the Court: Completed Motion for Correction to PSR: September 24, 2012 Reply or Statement of Non-Opposition: October 1, 2012 The government has authorized the defense counsel for FERNANDO MORENO-CAMACHO to sign this stipulation on his behalf.
DATED: September 4, 2012 BENJAMIN WAGNER United States Attorney by /s/ Scott N. Cameron, for Todd Pickles Assistant U.S. Attorney DATED: September 4, 2012 by /s/ Scott N. Cameron Scott N. Cameron Counsel for: Fernando Moreno-Camacho
Good cause appearing, The date for judgment and sentencing of defendant FERNANDO MORENO-CAMACHO, presently scheduled for September 17, 2012, is continued to October 9, 2012, at 9:30 a.m. The Court also orders the briefing schedule as set forth in the above stipulation.
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