Opinion
No. CR-00-00303-JW
10-27-2011
UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL CANATELLA, Defendant.
STEVEN F. GRUEL Attorney for Michael Canatella DAVID HALL Assistant United States Attorney
STEVEN F. GRUEL (CSBN 213148)
Attorney at Law
Attorney for Michael Canatella
STIPULATION AND [PROPOSED] ORDER CONTINUING SENTENCING DATE
Honorable James Ware
Defendant Michael Canatella, by and through his attorney, Steven F. Gruel, and the United States of America, by and through his attorney, David Hall, hereby requests that the sentencing hearing set for October 31, 2011, be continued to November 7, 2011. The defendant is not in custody.
The basis for this stipulation is that: (1) the defense only received the latest version of the presentence report on October 26, 2011 and requests the additional time to respond accordingly; and (2) the defense has yet to receive the government's anticipated motion for a downward
STIPULATION AND [PROPOSED] ORDER CONTINUING SENTENCING DATE
departure motion pursuant to 5K1.1of the United States Sentencing Guidelines. This too must be received and reviewed in order to fully prepare and file the defendant's sentencing brief.
SO STIPULATED:
STEVEN F. GRUEL
Attorney for Michael Canatella
DAVID HALL
Assistant United States Attorney
[PROPOSED] ORDER
PREDICATED on the above stipulation and GOOD CAUSE APPEARING, defendant Michael Canatella's sentencing hearing is hereby continued to November 7, 2011. at 1:30 pm.
IT IS SO ORDERED.
HONORABLE JAMES WARE
Chief United States Judge