Opinion
Case No.: 2:11-cr-00442-GEB
07-09-2012
UNITED STATES OF AMERICA, Plaintiff, v. KEITH ANDREW BAIA, et. al., Defendants.
MICHAEL STEPANIAN Attorney for Defendant KEITH ANDREW BAIA RANDY SUE POLLOCK Attorney for Defendant JODY STEWART RICHARD J. BENDER Assistant U.S. Attorney
RANDY SUE POLLOCK
Attorney at Law (CSBN 64493)
Attorney for Defendant
JODY WEBER STEWART
MICHAEL STEPANIAN
Attorney at Law, CA SBN 037712
Attorney for Defendant
KEITH ANDREW BAIA
STIPULATION AND PROPOSED
ORDER TO CONTINUE SENTENCING
DATE AND FILING DATE FOR
SENTENCING MEMORANDA
IT IS HEREBY STIPULATED AND AGREED by Randy Sue Pollock, counsel for Jody Stewart, Michael Stepanian, counsel for Keith Baia, and Assistant United States Attorney Richard Bender that sentencing for both defendants in the above-referenced case which is presently set for July 13, 2012, be continued to August 10, 2012.
The reason for this continuance is that Defense Counsel Ms. Pollock is unable to complete her client's sentencing memorandum due to knee surgery, and further legal issues in connection with the presentence reports need to be resolved. Therefore, the defense requests that sentencing memoranda in this matter shall be due on August 3rd, 2012. The Government does not object to this request. Respectfully Submitted,
_________________
MICHAEL STEPANIAN
Attorney for Defendant
KEITH ANDREW BAIA
_________________
RANDY SUE POLLOCK
Attorney for Defendant
JODY STEWART
_________________
RICHARD J. BENDER
Assistant U.S. Attorney
SO ORDERED:
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GARLAND E. BURRELL, JR.
Senior United States District Judge