Opinion
CR 10-00012-EJD
10-26-2011
UNITED STATES OF AMERICA, Plaintiff, v. JASON HAGBERG, Defendant.
p] MELINDA HAAG UNITED STATES ATTORNEY JEFFREY D. NEDROW Assistant U.S. Attorney JULES BONJOUR Attorney for Jason Hagberg
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
JEFFREY D. NEDROW (CABN 161299)
Assistant United States Attorney
Attorneys for Plaintiff
STIPULATION TO CONTINUE SENTENCING HEARING
The United States, through its counsel Jeffrey Nedrow, and defendant Jason Hagberg, through his counsel Jules Bonjour, hereby agree and stipulate to continue the sentencing hearing in this case presently scheduled for Monday, October 31, 2011 at 1:30 p.m. to Monday, January 23, 2012 at 1:30 p.m. before this Court. This continuance is requested for the following reasons:
1) Both counsel are requesting additional time to prepare for sentencing in this case. The government requests additional time to evaluate information developed subsequent to the indictment in this case and to finalize its sentencing recommendation, and the defense requests additional time to respond to the government's recommendation.
For these reasons, the parties respectfully request that the Court continue the sentencing hearing in this case from October 31, 2011 to January 23, 2012 at 1:30 p.m. The probation office has been contacted regarding this requested continuance.
It is so stipulated.
Respectfully submitted,
MELINDA HAAG
UNITED STATES ATTORNEY
JEFFREY D. NEDROW
Assistant U.S. Attorney
JULES BONJOUR
Attorney for Jason Hagberg
ORDER
Based on the stipulation of the parties and the facts set forth herein, good cause appearing,
IT IS HEREBY ORDERED that date of the sentencing hearing in this case is continued from October 31, 2011 to January 23, 2012 at 1:30 p.m. before this Court.
EDWARD J. DAVILA
United States District Judge