Opinion
No. CR. S-09-289 GEB
09-26-2011
UNITED STATES OF AMERICA, Plaintiff, v. SHANNON FORD, et al., Defendant.
BRUCE LOCKE Attorney for Shannon Ford BRUCE LOCKE For LINDA HARTER Attorney for Michael Ford BRUCE LOCKE For MICHELLE RODRIGUEZ Assistant United States Attorney
BRUCE LOCKE (#177787)
Moss & Locke
Attorneys for
SHANNON FORD
STIPULATION AND [PROPOSED] ORDER CHANGING THE DATE
FOR SENTENCING FROM DECEMBER 16, 2011 TO OCTOBER 14, 2011 AT 9:00 A.M.
Stipulation
The defendant, Shannon Ford, by and through her attorney, Bruce Locke, the defendant Michael Ford, by and through his attorney, Linda Harter, and the United States, by and through its attorney, Michelle Rodriguez, hereby stipulate that the date for sentencing for Ms. Ford and the status conference for Mr. Ford, currently scheduled for December 16, 2011 at 9:00 a.m. should be changed to October 14, 2011 at 9:00 a.m.
At the status conference on September 16, 2011, counsel for the government and counsel for Ms. Ford advised the Court that the Probation Office needed an additional 60 days to finalize its recommendation of the amount that the defendant should be ordered to pay as restitution. Counsel made this representation based upon their understanding of what Ms. Moore needed to do before she could finalize her recommendation and because Ms. Moore, the Probation Officer on this case, was not present at the status conference. After conferring with Ms. Moore, counsel for the government and counsel for Ms. Ford realized that they had misunderstood what Ms. Moore was required to do and that Ms. Moore did not need any additional time to finalize her recommendation of the amount that should be ordered as restitution.
Further, Ms. Moore provided counsel for Ms. Ford with the information that she relied upon to make her preliminary recommendation of $32,096.76. Counsel for the defendant has reviewed this information and has provided Ms. Moore with additional information that shows that the Probation Office's calculation contained duplications and also included an amount that Ms. Ford has already paid back to the individual involved. Ms. Moore has accepted the defendant's objections to her original calculation and Ms. Moore, Ms. Rodriguez, and the defendant, Ms. Ford, and her defense counsel now all agree that the correct amount that the Court should order for restitution is $20,665.21.
As a result of this agreement among the parties, there is no need to delay Ms. Ford's sentencing to December 16, 2011 and the parties agree and stipulate that October 14, 2011 at 9:00 a.m., should be set as the day and time for sentencing. That date and time should also be the date and time set for the status conference for Mr. Ford. Ms. Harter and Ms. Rodriguez have authorized Mr. Locke to sign this Stipulation and Proposed Order for them.
BRUCE LOCKE
Attorney for Shannon Ford
BRUCE LOCKE
For LINDA HARTER
Attorney for Michael Ford
BRUCE LOCKE
For MICHELLE RODRIGUEZ
Assistant United States Attorney
Order
IT IS SO ORDERED.
GARLAND E. BURRELL, JR.
United States District Judge