Filed: Nov. 14, 2017
Latest Update: Nov. 14, 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, December 7, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to January 18, 2018 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, December 7, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to January 18, 2018 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, December 7, 2017 at 9:30 a.m., in the above-captioned matter, and to continue judgment and sentencing to January 18, 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"):
Written, or informal, objections December 21, 2017
Final PSR December 28, 2017
Motion for correction of PSR January 4, 2018
Government's reply January 11, 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 proof Ms. Collins' has obtained her GED, her college transcripts, and school and other records for Ms. Collins' oldest child, who was recently returned to her care after being a ward of the court. Ms. Radekin also needs additional time to review the arrest reports in the probation officer's possession pertaining to Ms. Collins' prior arrests, facts from which are set forth in the PSR, and to do other investigation and obtain records relating to Ms. Collins' criminal history. 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, December 7, 2017 at 9:30 a.m. is VACATED and the above-captioned matter is set for judgment and sentencing on January 18, 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:
Written, or informal, objections December 21, 2017
Final PSR December 28, 2017
Motion for correction of PSR January 4, 2018
Government's reply January 11, 2018
IT IS SO ORDERED.
