Stipulation to Continue Motion Hearing — USA v. Western Distribution, LLC. et al. (Dkt. 65, C.D. Cal.)

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Stipulation to Continue Motion Hearing with a proposed order, filed 08/01/22 as Document 65 in Case 5:21-cr-00170-JGB, Central District of California, in United States of America versus Carl Bradley Johansson and Western Distribution, LLC. Defense counsel and Assistant United States Attorneys Joseph Johns and Matthew O'Brien jointly ask the Court to move the motion hearing set for Tuesday, August 2, 2022 at 10:00 a.m. to 3:30 p.m. the same day. The stated good cause is that defense counsel have a preliminary hearing in the Los Angeles Superior Court in People v. Allan Neyman, a multi-defendant case likely to occupy the entire morning. Both signature blocks are dated July 30, 2022.

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oN DN WO BW NHN KF DODO WN HD NH BW NNO KF CO

Case 5:21-cr-00170-JGB Document65- Filed 08/01/22 Pagelof2 PageID#:35

Mark J. Werksman, Esq. (State Bar No. 120767)
Caleb E. Mason, Esq. § ate Bar No. 246653)
Karen M. Sosa, Esq. g tate Bar No. 318399)
WERKSMAN JA ON & QUINN, LLP

888 West Sixth Street, Fourth Floor cent, 1 ee court
Los Angeles, California 90017
Telephone: (213) 688-0460 8/1/22

Attorneys for Defendants

Carl Bradley Johansson

Western Distribution, LLC
UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, CASE NO.: 18-CR-00114-VAP
_ 21-CR-00170-VAP
Plaintiff,
STIPULATION TO CONTINUE
VS. MOTION HEARING; [PROPOSED]
ORDER
CARL BRADLEY JOHANSSON AND
WESTERN DISTRIBUTION, LLC, CURRENT DATE AND TIME:
AUGUST 2, 2022 AT 10:00 A.M.
Defendants.
PROPOSED DATE AND TIME:

AUGUST 2, 2022 AT 3:30 P.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 agree to request that the Court continue the motion hearing currently
set for Tuesday, August 2, 2022 at 10:00 a.m. be continued to the afternoon at 3:30

p.m.

///
oN DN WO BW NHN KF DODO WN HD NH BW NNO KF CO

Case 5:21-cr-00170-JGB Document65- Filed 08/01/22 Page2of2 PageID#:35

Good cause exists for this continuance, as defense counsel has a preliminary
hearing set in the Los Angeles Superior Court for People v. Allan Neyman, a multi-
defendant case that likely will require them to be present throughout the entire

morning of August 2, 2022.

IT IS SO STIPULATED.

DATED: July 30, 2022 Respectfully submitted,

Mark J. Werksman

Karen M. Sosa

Attorneys for Defendants

CARL BRADLEY JOHANSSON and
WESTERN DISTRIBUTION, LLC.

DATED: July 30, 2022

Joseph Johns

Matthew O’Brien

Assistant United States Attorneys
Attorneys for Plaintiff

UNITED STATES OF AMERICA


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