Filed: Sep. 28, 2017
Latest Update: Sep. 28, 2017
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, October 26, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to December 7, 2017 at 9:30 a
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, October 26, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to December 7, 2017 at 9:30 a...
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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, October 26, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to December 7, 2017 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"):
Written, or informal, objections November 9, 2017
Final PSR November 16, 2017
Motion for correction of PSR November 22, 2017
Government's reply November 30, 2017
The reason for this request is that the defense needs additional time to prepare for sentencing, for the following reasons. First, court proceedings relating to the custody of one of Ms. Collins' children, who is presently a ward of the court, are scheduled for October 4, 2017. On that date, the court will decide whether to return custody of the child to Ms. Collins. The outcome of such proceedings and documents relating to those proceedings are relevant to Ms. Collins' rehabilitation and thus important mitigating evidence for use at sentencing. Efforts to obtain documents used in these proceedings have been impeded because, in the last 30 days, one of the two investigators working on this case had a baby, and is presently on maternity leave, and the other was out for recovery from surgery. Further, Ms. Radekin has a long-planned vacation from September 30, 2017 to October 11, 2017. The Court is advised Ms. Rust and Ms. 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, October 26, 2017 at 9:30 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on December 7, 2017 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:
Written, or informal, objections November 9, 2017
Final PSR November 16, 2017
Motion for correction of PSR November 22, 2017
Government's reply November 30, 2017
IT IS SO ORDERED.
