STIPULATION AND ORDER TO CONTINUE JUDGMENT AND SENTENCING

WILLIAM B. SHUBB, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Brian Fogerty, defendant, Sandra Hermosillo, by and through her counsel, Erin J. Radekin, defendant, Jun Michael Dirain, by and through his counsel, Timothy Zindel, defendant, Manuel Herrera, by and through his counsel, John Manning, and defendant, Moctezuma Tovar, by and through his counsel, Thomas A. Johnson, agree and stipulate to vacate the date set for judgment and sentencing, February 20, 2018 at 9:00 a.m., and to continue judgment and sentencing until May 14, 2018 at 9:00 a.m., in the courtroom of the Honorable William B. Shubb.

The reason for this request is that the government and the defendants need additional time to discuss and assess any departures under Section 5K1.1 of the U.S. Sentencing Guidelines for cooperation, and engage in other investigation and collection of documents relevant to sentencing. The Court is advised that all counsel listed above and U.S. Probation Officer Becky Fidelman concur with this request, and all counsel have 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 20, 2018 at 9:00 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on May 14, 2018 at 9:00 a.m. in the courtroom of the Honorable William B. Shubb.

IT IS SO ORDERED.