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UNITED STATES OF AMERICA, Plaintiff, v. MAURICE BELL, Defendant.

RICHARD SEEBORG

STEVEN G. KALAR
Federal Public Defender
RITA BOSWORTH
Assistant Federal Public Defender
450 Golden Gate Avenue
San Francisco, CA 94102
Telephone: (415) 436-7700
Telefacsimile: (415) 436-7706
Counsel for Defendant BELL







STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING
Current hearing date: May 7, 2013
Proposed hearing date: May 21, 2013

1. On January 29, Mr. Bell pled guilty to one count of theft of government property. His sentencing date was set for May 7. 2. Defense counsel has since learned that she will be out of the district for work on May 7. In order to assure that Mr. Bell's lawyer is present during his sentencing hearing, a critical stage of his proceedings, it is necessary to continue his sentencing. 3. According to the Court's calendar, the Court is not available the following week on May 14. Therefore, the parties request that Mr. Bell's sentencing hearing be re-set for May 21. 4. Mr. Bell is out of custody, so a continuance does not prejudice him in any way.

IT IS SO STIPULATED.

MELINDA HAAG


United States Attorney


_________________


HEATHER MELTON


Special Assistant United States Attorney


STEVEN KALAR


Federal Public Defender


_________________


RITA BOSWORTH


Assistant Federal Public Defender


In light of the parties' stipulation, it is hereby ORDERED that the sentencing hearing set for May 7, 2013, is VACATED and RESCHEDULE for May 21, 2013, at 2:30 p.m.

_________________


RICHARD SEEBORG


United States District Judge


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United States v. Bell
(May 1, 2013)