Opinion
2:20-cr-00059-APG-DJA
12-28-2022
UNITED STATES OF AMERICA, Plaintiff, v. ROBERT GUY RUSSELL, Defendant.
RENE L. VALLADARES Federal Public Defender JASON M. FRIERSON United States Attorney BRIAN PUGH Assistant Federal Public Defender EDWARD G. VERONDA Assistant United States Attorney
RENE L. VALLADARES Federal Public Defender
JASON M. FRIERSON United States Attorney
BRIAN PUGH Assistant Federal Public Defender
EDWARD G. VERONDA Assistant United States Attorney
STIPULATION TO CONTINUE SENTENCING (ELEVENTH REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between Jason M. Frierson, United States Attorney, and Edward G. Veronda, Assistant United States Attorney, counsel for the United States of America, and Rene L. Valladares, Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel for Robert Guy Russell, that the Sentencing Hearing currently scheduled on January 12, 2023 at 1:30 p.m., be vacated and continued to a date and time convenient to the Court, but no sooner than sixty (60) days.
This Stipulation is entered into for the following reasons:
1. In October, the government provided the defense with 4179 pages of discovery.
2. In November, the government provided the defense with additional discovery constituting approximately 1000 audio files. The defense needs additional time to review this discovery.
3. The defense and the government are attempting to negotiate an agreed upon recommended sentence for this Court. The parties need additional time to pursue such an agreement.
4. Defendant is not incarcerated and does not object to a continuance.
5. This continuance is not sought for the purposes of delay.
5. The parties agree to the continuance.
This is the eleventh request for continuance filed herein.
ORDER
Based on the Stipulation of counsel and good cause appearing, IT IS THEREFORE ORDERED that the Sentencing Hearing currently scheduled on January 12, 2023 at the hour of 1:30 p.m., be vacated and continued to March 23, 2023 at the hour of 9:30 a.m. in Courtroom 6C.