Free Stipulation - District Court of California - California

Case 3:07-cr-00336-WHA

Document 56

Filed 05/27/2008

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SCOTT A. SUGARMAN (No. 68277) SUGARMAN & CANNON 44 Montgomery St., Suite 2080 San Francisco, CA. 94104 Telephone: (415) 362-6252 Facsimile: (415) 677-9445 Attorneys for Defendant DEANDRE WATSON

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. DEANDRE WATSON, Defendant. ) ) ) ) ) ) ) ) ) No. CR 07-0336 WHA STIPULATION TO CONTINUE SENTENCING AND [proposed] ORDER

Defendant Deandre Watson has entered a guilty plea in this matter, and sentencing is currently set for 10:00 a.m. on June 3, 2008. The United States Probation Office has recently provided to both counsel its final Presentence Report.

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Counsel for Deandre Watson and counsel for the government jointly ask this Court to
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continue the sentencing from June 3, 2008 to July 22, 2008.
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Counsel for Mr. Watson will not be able to file a timely Sentencing Memorandum and response to the Presentence Report due to obligations and responsibilities for other clients. On May 16, 2008, counsel for Watson filed a Response to a Petition for Rehearing en banc in the United States Court of Appeals for the Ninth Circuit at the request of that Court in response to the Petition for Rehearing by the California Attorney General following that Court's decision ordering the immediate release of counsel's client in a federal habeas corpus appeal. Further, Watson's

Stipulation to Continue Sentencing

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Case 3:07-cr-00336-WHA

Document 56

Filed 05/27/2008

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counsel has to file this week a Petition for Review in the California Supreme Court to seek review of a decision of the California Court of Appeal affirming the conviction and life sentence of another of counsel's clients. As a result of those responsibilities, and other court appearances, counsel will not be able to file the necessary Sentencing Memorandum with this Court. When counsel for Watson discussed these problems with government counsel, government counsel stated that he had no objection to continuing sentencing and would join in this Stipulation. Counsel for Watson and/or the government are not available on this Court's regular sentencing dates for the remainder of June 2008 or the first week of July 2008. This Court's clerk advised counsel that this Court was available on July 22, 2008 for sentencing in this matter, and both

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counsel are available that day.
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Counsel for the government and counsel for defendant Deandre Watson hereby request and
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STIPULATE to continue sentencing for Deandre Watson from June 3, 2008 to July 22, 2008 at 10:00 a.m. The United States Probation Department has been advised of these circumstances and has informed counsel for Deandre Watson that it has no objection to this requested continuance. SO STIPULATED. DATED: May 27, 2008 _______/s/_______________________ Scott A. Sugarman Attorney for Deandre Watson

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DATED: May 27, 2008

______/s/________________________ William Frentzen Assistant United States Attorney

SO ORDERED. DATE: ____________________________ WILLIAM H. ALSUP UNITED STATES DISTRICT COURT

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Stipulation to Continue Sentencing

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