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USA v. Keys, 2:16-cr-00234-GEB. (2018)

Court: District Court, E.D. California Number: infdco20180130769 Visitors: 21
Filed: Jan. 23, 2018
Latest Update: Jan. 23, 2018
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE JUDGMENT AND SENTENCING GARLAND E. BURRELL, JR. , Senior District Judge . STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Thomas Nelson Keys, by and through his attorney, Erin J. Radekin, agree and stipulate to vacate the date currently set for judgment and sentencing, February 16, 2018 at 9:00 a.m., in the above-captioned matter, and to continue the status
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE JUDGMENT AND SENTENCING

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Thomas Nelson Keys, by and through his attorney, Erin J. Radekin, agree and stipulate to vacate the date currently set for judgment and sentencing, February 16, 2018 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to March 2, 2018 at 9:00 a.m. in the courtroom of the Honorable Garland E. Burrell, Jr.

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 February 7, 2018 Final PSR February 9, 2018 Motion for correction of PSR February 16, 2018 Government's reply February 23, 2018

The reason for this request is that additional time is needed by the defense to complete investigation into mitigation for use at sentencing, and completion of the informal objections. The Court is advised that Mr. Hitt and Probation Officer Nisha Modica concur with this request and 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 judgment and sentencing date of February 16, 2018 at 9:00 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on March 2, 2018 at 9:00 a.m.

Further, the schedule of disclosure relating to the PSR is modified as follows:

Written, or informal, objections February 7, 2018 Final PSR February 9, 2018 Motion for correction of PSR February 16, 2018 Government's reply February 23, 2018

IT IS SO ORDERED.

Source:  Leagle

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