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U.S. v. BRUNING, 2:13-cr-00291 MCE. (2015)

Court: District Court, E.D. California Number: infdco20151216a39 Visitors: 14
Filed: Dec. 14, 2015
Latest Update: Dec. 14, 2015
Summary: STIPULATION AND ORDER TO CONTINUE SENTENCING DATE MORRISON C. ENGLAND, Jr. , Chief District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant BROOKE BRUNING, by and through her counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for sentencing on December 17, 2015 at 9:00 a.m. 2. By this stipulation, defendant now moves to continue the sentencing date until March 10, 2016 at 9:00 a.m. Plaintif
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STIPULATION AND ORDER TO CONTINUE SENTENCING DATE

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant BROOKE BRUNING, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for sentencing on December 17, 2015 at 9:00 a.m.

2. By this stipulation, defendant now moves to continue the sentencing date until March 10, 2016 at 9:00 a.m. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. On September 17, 2015, Ms. Bruning plead guilty to Conspiracy to Distribute and Possess with Intent to Distribute LSD and DMT in violation of 21 U.S.C. §§ 846 and 841(a)(1). b. Ms. Bruning is a single mother of a 23-month old daughter who has Erb's Palsy, a paralysis of the arm caused by injury to the upper arm's main nerves. Because of her condition, Ms. Bruning's daughter requires multiple surgeries. Her first surgery occurred when she was six months old. Ms. Bruning's daughter is scheduled to undergo a second surgery on December 23, 2015. Following the surgery, Ms. Bruning's daughter will be in a spica cast for 30-days and will require several days of out patient physical therapy. c. Counsel for Ms. Bruning desires additional time to allow Ms. Bruning to focus on her daughter's upcoming surgery and to allow counsel to prepare a sentencing memorandum. d. Counsel for Ms. Bruning believes that good cause exists for a continuance. e. The Government does not object to the continuance. The time for filing a sentencing memorandum or motion, or any response thereto, in accordance with this Court's Minute Order dated September 17, 2015, shall be based on the new hearing date.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.

Source:  Leagle

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