Opinion
No.: CR-S 08-0474 EJG
07-24-2012
JOSEPH J. WISEMAN Attorney for Defendant Behrooz Badie BENJAMIN B. WAGNER United States Attorney By: Todd Leras TODD LERAS Assistant U.S. Attorney
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
BEHROOZ BADIE
STIPULATION AND PROPOSED
ORDER TO CONTINUE SENTENCING
It is hereby stipulated and agreed to between Plaintiff, UNITED STATES OF AMERICA, through its counsel of record, Todd Leras, Assistant United States Attorney, and Defendant, BEHROOZ BADIE, through his counsel of record, Joseph J. Wiseman, and without objection from the United States Probation Officer assigned to this case, that the sentencing of Defendant now scheduled for August 24, 2012 at 9:00 a.m., be rescheduled to September 21, 2012, at 9:00 a.m.
The Presentence Report has been provided to counsel. Pursuant to this stipulation, the Defendant's informal Objections shall be filed with the probation officer on August 24, 2012, the Presentence Report shall be filed with the Court on August 31, 2012, Motion to Correct the Presentence Report shall be due on September 7, 2012, and Opposition/Reply to said motion shall be due on September 14, 2012.
The parties are requesting this continuance because counsel needs additional time to review the PSR with Mr. Badie. Additionally, counsel believes Mr, Badie's sentencing could be affected by the loss amount and needs additional time to research the loss.
Respectfully submitted,
WISEMAN LAW GROUP, P.C.
By: Joseph J. Wiseman
JOSEPH J. WISEMAN
Attorney for Defendant
Behrooz Badie
BENJAMIN B. WAGNER
United States Attorney
By: Todd Leras
TODD LERAS
Assistant U.S. Attorney
ORDER
GOOD CAUSE HAVING BEEN SHOWN, IT IS HEREBY ORDERED THAT the sentencing of Defendant BEHROOZ BADIE in the above-captioned case shall be continued to September 21,2012 at 10:00 a.m. The Defendant's informal Objections shall be filed with the probation officer on August 24, 2012, the Presentence Report shall be filed with the Court on August 31, 2012, Motion to Correct the Presentence Report shall be due on September 7, 2012, and Opposition/Reply to said motion shall be due on September 14 2012. Any sentencing memoranda are-due on September 18,2012.
________________
EDWARD J. GARCIA
UNITED STATES DISTRICT JUDGE