Opinion
Case No. CR.S. 2:11 0209 GEB
02-07-2013
UNITED STATES OF AMERICA, Plaintiff, v. DAVID ROMO, Defendant.
Respectfully submitted, WISEMAN LAW GROUP, P.C. JOSEPH J. WISEMAN Attorney for Defendant David Romo BENJAMIN B. WAGNER United States Attorney MICHAEL D. ANDERSON Assistant U.S. Attorney Attorney for the United States
JOSEPH J. WISEMAN, ESQ., CSBN 107403
WISEMAN LAW GROUP, P.C.
1477 Drew Avenue, Suite 106
Davis, California 95618
Telephone: 530.759.0700
Facsimile: 530.759.0800
Attorney for Defendant
DAVID ROMO
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE SENTENCING
IT IS HEREBY STIPULATED by the parties, The UNITED STATES OF AMERICA, through undersigned counsel, Michael D. Anderson, Assistant United States Attorney, and Joseph J. Wiseman, attorney for defendant DAVID ROMO, without objection from the United States Probation Officer assigned to this case, that the sentencing of Defendant now scheduled for March 1, 2013 at 9:00 a.m., be rescheduled to, April 19, 2013 at 9:00 a.m.
Pursuant to this stipulation, the Proposed Presentence Report shall be disclosed to Counsel no later than March 8, 2013, Defendant's Written Objections shall be due March 22, 2013, Pre-Sentence Report shall be filed with the Court March 29, 2013, Defendant's Motion to Correct the Presentence Report shall be due on April 5, 2013, and Plaintiff's Opposition/Reply to said motion shall be due on April 12, 2013.
The parties are requesting this continuance to allow counsel additional time to provide probation with information relating to the loss calculation. IT IS SO STIPULATED.
Respectfully submitted,
WISEMAN LAW GROUP, P.C.
By: ____________________________
JOSEPH J. WISEMAN
Attorney for Defendant
David Romo
BENJAMIN B. WAGNER
United States Attorney
By: Joseph J. Wiseman
For: Michael D. Anderson
MICHAEL D. ANDERSON
Assistant U.S. Attorney
Attorney for the United States
PROPOSED ORDER
GOOD CAUSE HAVING BEEN SHOWN, IT IS HEREBY ORDERED THAT the sentencing in the above-captioned case be continued to APRIL 19, 2013, at 9:00 a.m. and the other dates adjust as noted by stipulation. IT IS SO ORDERED.
____________________________
GARLAND E. BURRELL, JR.
Senior United States District Judge