Opinion
3:22-cr-00047-ART-CSD
11-21-2022
UNITED STATES OF AMERICA, Plaintiff, v. JERRY MICHAEL FAMBRO, Defendant.
RENE L. VALLADARES Federal Public Defender ALLIE WILSON Assistant Federal Public Defender Counsel for JERRY FAMBRO JASON M. FRIERSON United States Attorney ANDREW KEENAN Assistant United States Attorney Counsel for the Government
RENE L. VALLADARES Federal Public Defender ALLIE WILSON Assistant Federal Public Defender Counsel for JERRY FAMBRO
JASON M. FRIERSON United States Attorney ANDREW KEENAN Assistant United States Attorney Counsel for the Government
STIPULATION TO CONTINUE SENTENCING HEARING (FIRST REQUEST)
Anne R. Traum United States District Judge
IT IS HEREBY STIPULATED AND AGREED by and through RENE L. VALLADARES, Federal Public Defender and ALLIE WILSON, Assistant Federal Public Defender, counsel for JERRY MICHAEL FAMBRO and JASON M. FRIERSON, United States Attorney, and ANDREW KEENAN, Assistant United States Attorney, counsel for the UNITED STATES OF AMERICA, that the Sentencing hearing set for November 29, 2022, at 1:00 PM, be vacated and continued to January 24, 2023, at 1:00 PM.
The continuance is necessary for the following reasons:
1. This is a joint request by counsel for the Government and counsel for the Defendant, Mr. Fambro.
2. The additional time requested by this Stipulation is reasonable pursuant to Federal Rule of Criminal Procedure 32(b)(2), which states that the “court may, for good cause, change any time limits prescribed in this rule.”
3. Both counsel request this additional time in order to allow adequate time to research sentencing issues and to prepare for the sentencing hearing.
4. Mr. Fambro is detained and agrees to the continuance. Specifically, Mr. Fambro was informed that the continuance will allow defense counsel to continue to gather documents in support of the hearing and provide continuity of counsel.
5. This is the first request for continuance of the sentencing hearing.
ORDER
Based on the Stipulation of counsel, and good cause appearing, IT IS THEREFORE ORDERED that the Sentencing Hearing currently set for November 29, 2022, at 1:00 PM, be vacated and continued to January 24, 2023, at 1:00 P.M.