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USA v. Khoonsrivong, 2:15-cr-00176-TLN-7. (2018)

Court: District Court, E.D. California Number: infdco20180131b02 Visitors: 5
Filed: Jan. 29, 2018
Latest Update: Jan. 29, 2018
Summary: STIPULATION AND ORDER TO CONTINUE JUDGMENT AND SENTENCING TROY L. NUNLEY , District Judge . STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Rosanne Rust, and defendant, Amber Collins, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for judgment and sentencing, February 8, 2018 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to March 1, 2018 at 9:30 a.m.
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STIPULATION AND ORDER TO CONTINUE JUDGMENT AND SENTENCING

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Rosanne Rust, and defendant, Amber Collins, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for judgment and sentencing, February 8, 2018 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to March 1, 2018 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.

In addition, the parties stipulate to the following modification to the schedule of disclosure relating to the pre-sentence report ("PSR"):

Motion for correction of PSR February 15, 2018 Government's reply February 22, 2018

The reason for this request is that the defense needs additional time to obtain and review records relevant to sentencing issues, and to prepare for sentencing. Such records include a spreadsheet prepared by the government and recently provided to the defense relating to restitution; police reports underlying Ms. Collins's prior arrests, which are summarized in the PSR; and records relating to Ms. Collins's children. The Court is advised Ms. Rust and United States Probation Officer Lynda Moore have no opposition to the proposed dates set forth above, and Ms. Rust has authorized Ms. Radekin to sign this stipulation on her 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 8, 2018 at 9:30 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on March 1, 2018 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.

It is FURTHER ORDERED that the schedule of disclosure be modified as follows:

Motion for correction of PSR February 15, 2018 Government's reply February 22, 2018

IT IS SO ORDERED.

Source:  Leagle

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