STIPULATION TO CONTINUE SENTENCING HEARING AND PROPOSED ORDER

LAWRENCE J. O'NEILL, Chief District Judge.

IT IS HEREBY STIPULATED by and between the parties hereto that the Sentencing Hearing currently scheduled for September 24, 2018, at 10:00 a.m. be continued to October 22, 2018, at 10:00 a.m. before the Honorable Lawrence J. O'Neill.

IT IS ALSO STIPULATED by and between the parties herein that the parties' formal objections/sentencing Memo to the Presentence report shall become due on September 14, 2018.

The need for a continuance is based upon defense counsel's (W. Scott Quinlan) need for additional time in which to fully prepare the formal objections/sentencing memo as he will be out of the office from September 1 through September 10, 2018. September 10, 2018, had been the date scheduled for the formal objections/sentencing memo to be filed with the court. As such, counsel is unable to be fully prepared for the Sentencing Hearing in this matter, as currently scheduled.

This request by defense counsel has been relayed to the Government by Assistant U.S. Attorney Mark McKeon, who has no objection.

The parties stipulate and agree that time can be excluded from September 24, 2018, to, and including, October 22, 2018, based upon counsel's need to be able to adequately represent his client at sentencing, and that the ends of justice outweigh the public's and defendants' interest in a speedy resolution.

Under the circumstances set forth herein, it is respectfully suggested that good cause does exist for a continuance to the hereinabove-noted date.

IT IS SO STIPULATED.

ORDER

Good cause appearing therefor,

IT IS HEREBY ORDERED that the Sentencing Hearing currently scheduled on September 24, 2018, at 10:00 a.m., is continued to October 22, 2018, at 10:00 a.m. and the above-noted briefing schedule be followed.

IT IS SO ORDERED.