Opinion
CR-S-08-212-LKK
09-26-2011
UNITED STATES OF AMERICA, PLAINTIFF, v. RENE WRIGHT, et al., DEFENDANTS.
Respectfully submitted, BENJAMIN B. WAGNER UNITED STATES ATTORNEY Richard J. Bender ASSISTANT UNITED STATE ATTORNEY ATTORNEY FOR THE PLAINTIFF James R. Greiner Attorney for Defendant Rene Wright
JAMES R. GREINER, ESQ.
CALIFORNIA STATE BAR NUMBER 123357
LAW OFFICES OF JAMES R. GREINER
ATTORNEY FOR DEFENDANT
RENE WRIGHT
STIPULATION AND
ORDER TO CONTINUE JUDGMENT
AND SENTENCING TO
TUESDAY NOVEMBER 15, 2011
Plaintiff United States of America, by its counsel, Assistant United States Attorney, Mr. Richard Bender and defendant Ms. Rene Wright, by her attorney Mr. James R. Greiner, hereby stipulate and agree that the judgement and sentencing set for Tuesday, September 27, 2011, at 9:15 a.m. before the Honorable Senior United States District Court Judge, Lawrence K. Karlton, may be continued to Tuesday, November 15, 2011, at 9:15 a.m..
The Court's courtroom deputy, Ms. Ana Rivas, has been contacted to ensure the Court's calendar was available for that date and the Court is available on Tuesday, November 15, 2011.
The defense is requesting this continuance, without objection from the government or probation, to allow the defendant to complete the terms of her plea agreement.
The parties agree to the following Pre-Sentence Report disclosure dates:
The Proposed Pre-Sentence Report shall be disclosed to counsel no later than: October 11, 2011
Counsel's written objections to the Pre-Sentence Report shall be delivered to the Probation Officer and opposing counsel no later than: October 18, 2011
The Pre-Sentence Report shall be filed with the Court and disclosed to counsel no later than October 25, 2011
Motion for correction of the Pre-Sentence Report shall be filed with the Court and served on the Probation Officer and opposing counsel no later than: November 1, 2011
Reply or statement of non-opposition November 8, 2011
Judgment and sentencing date: November 15, 2011
Respectfully submitted,
BENJAMIN B. WAGNER
UNITED STATES ATTORNEY
Richard J. Bender
ASSISTANT UNITED STATE ATTORNEY
ATTORNEY FOR THE PLAINTIFF
James R. Greiner
Attorney for Defendant
Rene Wright
For the reasons stated in the parties' stipulation, the Court hereby orders that the date for sentencing is continued from September 27, 2011 to November 15, 2011 at 9:15 a.m., and the schedule for the disclosure of the Pre-Sentence Report is amended as set forth in the stipulation. FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
LAWRENCE K. KARLTON
SENIOR JUDGE
UNITED STATES DIATRICT COURT