Opinion
COLIN L. COOPER, SBN 144291, KELLIN R. COOPER, SBN 172111, DUSTIN GORDON, SBN 205216 COOPER LAW OFFICES, Attorneys for Defendant REGINALD THOMAS
MATTHEW MORRIS Assistant United States Attorney
STIPULATION AND ORDER TO CONTINUE SENTENCING
MORRISON C. ENGLAND, JR, CHIEF JUDGE
Defendant REGINALD THOMAS, by and through his attorney, Colin Cooper, the UNITED STATES, by and through Assistant United States Attorney Matthew Morris, hereby stipulate and agree to continue the sentencing in the above-captioned case set for January 8, 2015 to February 5, 2015, at 9:00 a.m.
The parties further stipulate and agree that the period from January 8, 2015 to February 5, 2015 is excludable from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161 (h)(7)(iv) for the effective preparation of counsel.
The requested continuance is based on the fact that the parties need more time to discuss the level of credit that Mr. Thomas should receive for his cooperation. Mr. Thomas' criminal history is unique and the defense believes that it is overstated. The parties need more time to consider Mr. Thomas' criminal history before the Government prepares a 5K1.1 letter for the court and the defense finishes its sentencing brief. Thus, the parties are asking to continue the sentencing until February 5, 2015.
ORDER
GOOD CAUSE APPEARING, in that it is the stipulation of the parties: the sentencing scheduled for January 8, 2015, at 9:00 a.m. is vacated and the matter is set for sentencing on February 5, 2015, at 9:00 a.m.
IT IS SO ORDERED.