Opinion
Case No. 2:12-CR-00192 -GEB
02-28-2013
UNITED STATES OF AMERICA Plaintiff, v. JED BARON, Defendant
PAUL A. HEMESATH Assistant United States Attorney DONALD H. HELLER Counsel for Defendant
DONALD H. HELLER, SBN 55717
DONALD H. HELLER,
A Law Corporation
701 University Avenue, Suite 100
Sacramento, CA 95825
Telephone: (916) 974-3500
Facsimile: (916) 520-3497
Attorneys for Defendant
Jed Baron
STIPULATION TO CONTINUE
SENTENCING AND [PROPOSED]
ORDER
It is hereby stipulated and agreed between Plaintiff, United States of America by and through Assistant United States Attorney Paul A. Hemesath, Esq. and Donald H. Heller, Esq., attorney for the defendant Jed Baron that:
1. Defendant Jed Baron was scheduled for imposition of judgment and sentencing March 15, 2013.
2. Because of Attorney Donald H. Heller's illness, defendant's probation interview with U.S. Probation Officer Lynda Moore had to be re-scheduled to Thursday February 21, 2013, at the U.S. Marshal's custody facility at the U.S. Courthouse. The interview was conducted on February 21, 2013, and because of the delay it is necessary to continue the judgment and sentence to April 26, 2013.
3. Based on the continuance of Judgment and Sentence the Disclosure schedule is hereby changed as follows:
Reply or Statement of No Opposition................... 4/19/2013
(1 week before sentencing)
Motion for Correction of the Pre-Sentence Report
Shall be Filed with the Court and Served on the
Probation Officer and Opposing Counsel no
Later Than................... 4/12/2013
(2 weeks before sentencing)
The Pre-Sentence Report Shall be Filed with the
Court and Disclosed to Counsel no Later Than................... 4/05/2013
(3 weeks before sentencing)
Counsel's Written Objections to the Pre-Sentence
Report Shall be Delivered to the Probation Officer
and Opposing Counsel no Later Than................... 3/29/2013
(4 weeks before sentencing)
The Proposed Pre-Sentence Report Shall be Disclosed
to Counsel no Later Than................... 3/15/2013
(6 weeks before sentencing)
IT IS SO STIPULATED.
________________
PAUL A. HEMESATH
Assistant United States Attorney
________________
DONALD H. HELLER
Counsel for Defendant
ORDER
GOOD CAUSE APPEARING, the sentencing date of March 15, 2013 is vacated and judgment and sentencing is hereby reset to April 26, 2013 and the Disclosure Schedule stipulated above is hereby adopted.
________________
GARLAND E. BURRELL, JR.
Senior United States District Judge