Filed: Jan. 28, 2013
Latest Update: Jan. 28, 2013
Summary: STIPULATION AND ORDER FOR CONTINUANCE OF JUDGMENT AND SENTENCING AND MODIFICATION OF SCHEDULE OF DISCLOSURE JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Anthony C. Cavaness, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for judgment and sentencing in the above-captioned matter, February 26, 2013 at 9:45 a.m., and to continue jud
Summary: STIPULATION AND ORDER FOR CONTINUANCE OF JUDGMENT AND SENTENCING AND MODIFICATION OF SCHEDULE OF DISCLOSURE JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Anthony C. Cavaness, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for judgment and sentencing in the above-captioned matter, February 26, 2013 at 9:45 a.m., and to continue judg..
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STIPULATION AND ORDER FOR CONTINUANCE OF JUDGMENT AND SENTENCING AND MODIFICATION OF SCHEDULE OF DISCLOSURE
JOHN A. MENDEZ, District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Anthony C. Cavaness, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for judgment and sentencing in the above-captioned matter, February 26, 2013 at 9:45 a.m., and to continue judgment and sentencing to April 9, 2013 at 9:45 a.m. in the courtroom of the Honorable John A. Mendez.
In addition, the parties stipulate to the following modification to the schedule of disclosure:
Proposed pre-sentence report February 26, 2013
Informal objections to the pre-sentence report March 12, 2013
Final pre-sentence report March 19, 2013
Motion for correction of the pre-sentence report March 26, 2013
Government's reply, or statement of non-opposition April 2, 2013
The reason for this request is that Ms. Radekin needs additional time to complete her investigation into mitigating circumstances for use at sentencing. Ms. Radekin has communicated via email with investigator, M.E. Greenwood, and psychologist, Rahn Minagawa, both of whom have been appointed to prepare reports for use in support of mitigation at sentencing. They project that their reports will be complete around February 4, 2013. This should afford adequate time for United States Probation Officer Lisa Hage to review the reports and prepare the pre-sentence report by the above date. The court is advised that Ms. Radekin has discussed this matter with Mr. Hitt and Ms. Hage and they have no objection to this request or the dates proposed above. The court is further advised that Mr. Hitt has authorized Ms. Radekin to sign this stipulation on his behalf.
Accordingly, the parties respectfully request the court adopt this proposed stipulation. IT IS SO STIPULATED
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the date set for judgment and sentencing, February 26, 2013 at 9:45 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on April 9, 2013 at 9:45 a.m. in the courtroom of the Honorable John A. Mendez.
IT IS FURTHER ORDERED that the schedule of disclosure be modified as follows:
Proposed pre-sentence report February 26, 2013
Informal objections to the pre-sentence report March 12, 2013
Final pre-sentence report March 19, 2013
Motion for correction of the pre-sentence report March 26, 2013
Government's reply, or statement of non-opposition April 2, 2013
IT IS SO ORDERED.
