Filed: Jul. 12, 2019
Latest Update: Jul. 12, 2019
Summary: STIPULATION AND ORDER TO CONTINUE SENTENCING DALE A. DROZD , District Judge . WHEREAS the Sentencing Hearing has been scheduled in this matter for July 15, 2019. WHEREAS Roger S. Bonakdar, counsel for Defendant Marco Mosqueda (herein "Mr. Mosqueda") requests a continuance of the July 15, 2019, Sentencing so that he may meet with Mr. Mosqueda and to complete steps necessary for the Government to, and for the Court to apply, a "safety valve" and First Step compliant sentence. This will resul
Summary: STIPULATION AND ORDER TO CONTINUE SENTENCING DALE A. DROZD , District Judge . WHEREAS the Sentencing Hearing has been scheduled in this matter for July 15, 2019. WHEREAS Roger S. Bonakdar, counsel for Defendant Marco Mosqueda (herein "Mr. Mosqueda") requests a continuance of the July 15, 2019, Sentencing so that he may meet with Mr. Mosqueda and to complete steps necessary for the Government to, and for the Court to apply, a "safety valve" and First Step compliant sentence. This will result..
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STIPULATION AND ORDER TO CONTINUE SENTENCING
DALE A. DROZD, District Judge.
WHEREAS the Sentencing Hearing has been scheduled in this matter for July 15, 2019.
WHEREAS Roger S. Bonakdar, counsel for Defendant Marco Mosqueda (herein "Mr. Mosqueda") requests a continuance of the July 15, 2019, Sentencing so that he may meet with Mr. Mosqueda and to complete steps necessary for the Government to, and for the Court to apply, a "safety valve" and First Step compliant sentence. This will result in changes to the PSR and further informal and formal objections.
WHEREAS Mr. Mosqueda has not yet debriefed. This debriefing will have a significant impact on Mr. Mosqueda's sentencing guideline calculation, for safety valve purposes.
Further, Mr. Mosqueda has not completed the sentencing video. Additional time is required to complete the sentencing video.
WHEREAS counsel for the parties have met and conferred concerning the continuance, and the Government and Probation are in agreement.
THEREFORE, IT IS STIPULATED by and between the parties that the July 15, 2019, sentencing hearing be continued to October 21, 2019, or in the alternative to a date not less than 90 days from the July 15, 2019, sentencing date.
THEREFORE, IT IS FURTHER STIPULATED that this Stipulation may be executed in multiple counterparts, and that said counterparts (when offered together) shall constitute a fully executed original. In this regard, signatures by facsimile shall be given the same force and effect as originals.
IT IS SO STIPULATED:
Dated: July 11, 2019 United States Attorney's Office
By: /s/ Melanie L. Alsworth
MELANIE L. ALSWORTH
Assistant United States Attorney
Dated: July 11, 2019 UNITED STATES PROBATION
/s/ Megan D. Pascual
MEGAN D. PASCUAL
United States Probation Officer
Dated: July 11, 2019 BONAKDAR LAW FIRM
By: /s/ Roger S. Bonakdar
ROGER S. BONAKDAR
Attorney for Defendant
MARCO MOSQUEDA
ORDER
The Stipulation to Continue Sentencing Hearing having come before this Court and good cause appearing therefore;
IT IS HEREBY ORDERED that the July 15, 2019, Sentencing hearing is hereby continued to October 22, 2019.
IT IS FURTHER ORDERED that the deadlines for exchange of informal objections, and filing of formal objections and sentencing memoranda, shall be extended to reconcile with the continued Sentencing Hearing date.
IT IS SO ORDERED.
