Opinion
CASE NO.: 1:07-CR-00192 AWI
03-20-2013
HARRY M. DRANDELL, Attorney for Defendant, David Chavez, Sr. KATHLEEN A. SERVATIUS Attorney for Plaintiff, United States of America
HARRY M. DRANDELL #109293
LAW OFFICES OF HARRY M. DRANDELL
1221 VAN NESS AVENUE, SUITE 450
FRESNO, CA 93721
PHONE (559) 442-8888
FAX (559) 442-8891
ATTORNEYS FOR Defendant, David Chavez, Sr.
STIPULATION AND ORDER
TO CONTINUE SENTENCING
Date: March 25, 2013
HON. ANTHONY W. ISHII
IT IS HEREBY STIPULATED by and between the parties hereto and through their attorneys of record that the sentencing hearing presently scheduled before the Honorable Anthony W. Ishii for March 25, 2013, at 10:00 a.m., be continued to either July 8, 2013, or July 15, 2013, at 10:00 a.m.
This continuance is requested due to the fact that defendant needs additional time in which to file a Sentencing Memorandum, and because Mr. Chavez's wife of 33 years has recently been diagnosed with Stage 4 Ovarian cancer and is undergoing various and extensive medical treatment wherein defendant is the driver for said appointments. Mrs. Chavez is in her second month of chemotherapy which is scheduled to be completed on July 2, 2013. In addition, she is required to attend periodic medical appointments, which include PET Scans, as well as injections to raise her white blood cell count. As to each and every medical appointment the defendant drives Mrs. Chavez, as there is no one else available to do so.
All parties herein, through their respective counsel have been contacted regarding the requested continuance and concur with this request.
IT IS SO STIPULATED:
_________________
HARRY M. DRANDELL,
Attorney for Defendant, David Chavez, Sr.
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KATHLEEN A. SERVATIUS
Attorney for Plaintiff, United States of America
IT IS HEREBY ORDERED that the sentencing hearing presently set for March 25, 2013, at 10:00 a.m. is continued to July 8, 2013 , at 10:00 a.m. to be heard before the Honorable Anthony W. Ishii, Courtroom 2. IT IS SO ORDERED.
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SENIOR DISTRICT JUDGE