Free Stipulation - District Court of California - California

Case 5:07-cr-00610-JF

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Filed 03/25/2008

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JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney BRIAN J. STRETCH (CASBN 163973) Chief, Criminal Division JOSEPH A. FAZIOLI (ILSBN 6273413) Assistant United States Attorney 150 Almaden Boulevard, Suite 900 San Jose, California 95113 Telephone: (408) 535-5061 Facsimile: (408) 535-5081 E-Mail: [email protected] Attorneys for the United States

9 10 11 12 13 14 UNITED STATES OF AMERICA, 15 Plaintiff, 16 v. 17 BERNADETTE ESCUE, 18 Defendant. 19 20 21 22 23 24 25 26 27 28 ) ) ) ) ) ) ) ) ) ) ) No. CR 07-00610 JF STIPULATION AND [PROPOSED] ORDER RESCHEDULING SENTENCING UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

The sentencing of the defendant (who is out of custody) is currently scheduled for Wednesday, April 16, 2008. The United States now requests that defendant's sentencing be rescheduled to April 30, 2008. Defense counsel does not oppose this request. Undersigned government counsel has a scheduling conflict that now prevents him from attending sentencing on April 16, 2008. In addition, the parties would like additional time to resolve any potential objections to the presentence report and to make their respective sentencing recommendations. The probation officer assigned to this case, Lori Timmons, has indicated that she would be available for sentencing on April 30, 2008. It is the parties' understanding that the Court is also available on April 30, 2008.
STIPULATION AND [PROPOSED ] ORDER CR 07-00610 JF

Case 5:07-cr-00610-JF

Document 22

Filed 03/25/2008

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In light of the above, the parties agree, and the Court finds and holds, as follows: This matter is set for sentencing on April 30, 2008, at 9:00 a.m.

STIPULATED: DATED:____03/25/08_____ _______/s/______________________ MARK R. VERMEULEN Attorney for Defendant

DATED:____3/25/08______

_______/s/______________________ JOSEPH A. FAZIOLI Assistant United States Attorney

IT IS SO ORDERED. DATED:________________ _______________________________ JEREMY FOGEL UNITED STATES DISTRICT JUDGE

STIPULATION AND [PROPOSED ] ORDER CR 07-00610 JF