Opinion
Case No. 3:09-00036
10-26-2012
UNITED STATES OF AMERICA v. JAMES J. LANG
Chief Judge Haynes
MOTION TO CONTINUE SENTENCING DATE
COMES NOW the Defendant, James J. Lang, by and through his undersigned counsel and respectfully requests that this Honorable Court enter an order continuing the sentencing hearing in the above-captioned case from Friday, October 26, 2012 at 4:00 p.m., to a later date convenient to the Court and counsel. In support hereof, Defendant states as follows:
1. The sentencing hearing in this case is currently scheduled for Friday, October 26, 2012 at 4:00 p.m.
2. On July 22, 2011, some fifteen months ago, the Defendant filed his Motion for a Mitigated Sentence and Variance Below the Sentencing Guidelines. (Docket Entry 72). Last night, at approximately 5:46 p.m., the government filed a 15-page response to the Defendant's motion citing many cases which undersigned counsel will need to read and distinguish. (Docket Entry 90). Counsel will also need to review the factual assertions contained in the government's pleading with Mr. Lang. These exercises will likely result in the need for the Defendant to file a reply.
WHEREFORE, based on the foregoing, Defendant Lang respectfully requests that this Honorable Court enter an order continuing the sentencing hearing in the above-captioned case from Friday, October 26, 2012 at 4:00 p.m., to a later date convenient to the Court and counsel.