STEVEN G. KALAR, Federal Public Defender, ELIZABETH M. FALK, Assistant Federal Public Defender, San Francisco, CA. Counsel for Defendant TSANG.
ANDREW SCOBLE, ASSISTANT UNITED STATES ATTORNEY.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING
EDWARD M. CHEN, District Judge.
The parties hereby agree and stipulate to move the sentencing in Mr. Tsang's case from September 25, 2013 to March 12, 2014 at 2:30 p.m. The purpose of the requested continuance is to ensure that Mr. Tsang remains out of custody for the birth of his first child, a daughter. Mr. Tsang's wife is currently 18 weeks pregnant, and tests thus far reveal that the baby is healthy. The due date for the baby is in early February. A sentencing in the middle of March will ensure Mr. Tsang's presence for the delivery and the first few weeks of his child's life.
Mr. Tsang was indicted in this case on February 5, 2012. He was released on a $150, 000 bond secured by property with supervision by U.S. Pretrial Services. To date, Mr. Tsang has been in full compliance with the terms and conditions of his release. He has completed the presentence report process and fully cooperated with U.S. Probation in providing all requested documentation and attending his presentence interview.
Probation Officer Leon Dang has been contacted by defense counsel, and has no objection to moving the sentencing to March, 2014. He further indicated to defense counsel that he is available any Wednesday in March 2014 and is in agreement with any date selected by the parties.
As indicated by his signature below, government counsel Andrew Scoble has no objection to continuing the sentencing to March 12, 2014 for the reasons stated.
The parties accordingly request the Court to continue sentencing in this matter to March 12, 2014 for the reasons stated.
IT IS SO STIPULATED.
For the reasons set forth above, the hearing in the aforementioned matter is hereby CONTINUED from September 25, ...