First Request to Continue Sentencing from 5/9/2022 — USA v. Western Distribution, LLC. et al. (Dkt. 53, C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 5:21-cr-00170-JGB · Doc. 53 · 2022-04-12 · Docket on CourtListener

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Mark J. Werksman, Esq. (State Bar No. 120767) 
Karen M. Sosa, Esq. (State Bar No. 318399) 
WERKSMAN JACKSON & QUINN, LLP 
888 West Sixth Street, Fourth Floor 
Los Angeles, California 90017 
Telephone: (213) 688-0460 
Facsimile: (213) 624-1942 
 
Attorneys for Defendants 
Carl Bradley Johansson and 
Western Distribution, LLC 
 
UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
 
 
Plaintiff, 
 
vs. 
 
 
WESTERN DISTRIBUTION, LLC., and 
CARL BRADLEY JOHANSSON, 
 
 
Defendants. 
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Case No.: 21-CR-170-VAP 
 
STIPULATION AND REQUEST TO 
CONTINUE SENTENCING 
 
[PROPOSED ORDER FILED 
SEPARATELY] 
 
Current Hearing Date: 5/9/2022 at 9:00a.m. 
 
Proposed Hearing Date: 8/22/2022 at 9:00 a.m. 
 
 
 
Defendants Carl Bradley Johansson (“Johansson”) and Western Distribution, LLC 
(“Western”), by and through their counsel of record, Mark J. Werksman and Karen M. Sosa, and 
the United States of America, by and through its counsel of record, the United States Attorney 
for the Central District of California and Assistant United States Attorneys Joseph Johns and 
Matthew O’Brien, hereby stipulate and request that the Court continue the sentencing in this 
matter from May 9, 2022 to August 22, 2022.  This continuance is requested for the following 
reasons: 
1. On September 29, 2021, defendants Johansson and Western pleaded guilty pursuant 
to a plea agreement with the government, and at that time the Court set a sentencing 
Case 5:21-cr-00170-JGB     Document 53     Filed 04/12/22     Page 1 of 2   Page ID #:298

 
 
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hearing date of May 9, 2022.  This is the parties’ first request for a continuance of the 
sentencing. 
2. Defendants Johansson and Western received the Pre-Sentence Investigation Report 
from Probation on April 4, 2022. 
3. Defendant Johansson notified his counsel of record on April 10, 2022 that he wishes 
to retain new counsel for himself and Western. 
4. Therefore, counsel for Johansson and Western will need time either to resolve this 
conflict or for new counsel to prepare for the sentencing. 
5. The parties therefore stipulate and request that the Court continue the sentencing in 
this matter from May 9, 2022 to August 22, 2022. 
6. The parties also seek to continue the deadline for submitting objections to the 
Presentence Report and sentencing position papers from April 18, 2022 to August 1, 
2022. 
 
IT IS SO STIPULATED. 
 
DATED: April 12, 2022 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
_________________________ 
 
 
 
 
 
 
Mark J. Werksman 
 
 
 
 
 
 
Karen M. Sosa 
 
 
 
 
 
 
Attorneys for Defendants 
 
 
 
 
 
 
CARL BRADLEY JOHANSSON and 
 
 
 
 
 
 
WESTERN DISTRIBUTION, LLC. 
 
DATED: April 12, 2022 
 
 
 
 
 
 
 
 
 
 
 
_________/s/______________ 
Joseph Johns 
 
 
 
 
 
 
Matthew O’Brien 
Assistant United States Attorneys 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
Case 5:21-cr-00170-JGB     Document 53     Filed 04/12/22     Page 2 of 2   Page ID #:299

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