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MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
JEFFREY D. NEDROW (CABN 161299)
Assistant United States Attorney
150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: (408) 535-5054
Facsimile: (408) 535-5066
Email: Jeff.Nedrow@usdoj.gov
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
KENNETH PEREIRA,
Defendant.
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CR 10-00012-EJD
STIPULATION TO CONTINUE
SENTENCING HEARING
The United States, through its counsel Jeffrey Nedrow, and defendant Kenneth Pereira,
through his counsel Michael Hingle, hereby agree and stipulate to continue the sentencing
hearing in this case presently scheduled for Monday, January 14, 2013 at 1:30 p.m. to Monday,
January 28, 2013 at 1:30 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
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORN
I
A
IT IS SO ORDERED
AS MODIFIED
Judge Edward J. Davila
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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 January 14, 2013 at 1:30 p.m to January 28, 2013. The probation office
has been contacted regarding this requested continuance.
It is so stipulated.
Respectfully submitted,
MELINDA HAAG
UNITED STATES ATTORNEY
January 10, 2013 _______/s/_______________
JEFFREY D. NEDROW
Assistant U.S. Attorney
January 10, 2013 _______/s/________________
MICHAEL HINGLE
Attorney for Kenneth Pereira
ORDER
Based on the stipulation of the parties and the facts set forth herein, good cause
appearing,
IT IS HEREBY ORDERED that the date of the sentencing hearing in this case is
continued from January 14, 2013 to January 29, 2013 at 1:30 p.m. before this Court.
Dated this _______ day of __________________, 2013.
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EDWARD J. DAVILA
United States District Judge
2
10th January