STIPULATION WITH PROPOSED ORDER to Continue Sentencing Hearing as to Frank Mosley,… — USA v. Mosley et al (Dkt. 41)

Record facts

U.S. District Court for the Northern District of California · No. 4:23-cr-00134-AMO · Doc. 41 · 2023-10-02 · Docket on CourtListener

Summary

A stipulation and proposed order to continue the sentencing hearing in United States v. Frank Mosley, Case No. 4:23-cr-00134-AMO, in the U.S. District Court for the Northern District of California, Oakland Division, filed October 2, 2023 as Document 41. Defense counsel Malcolm Segal and Assistant United States Attorney Abraham Fine ask that the sentencing hearing set for January 22, 2024 be continued to March 25, 2024. The stipulation states that defense counsel needs more time to help gather records for the meeting with the assigned probation officer and the pre-sentence report, and is scheduled for a lengthy criminal trial in Riverside County. The proposed order for Judge Araceli Martínez-Olguín continues sentencing to March 25, 2024, at 2:00 p.m. The filing ends with a certificate of service on the United States Probation Office.

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Full text

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
Malcolm Segal (SBN 075481)  
SEGAL & ASSOCIATES, PC 
500 Capitol Mall, Suite 600 
Sacramento, CA  95814 
Telephone: (916) 441-0886 
Facsimile: (916) 475-1231 
msegal@segal-pc.com 
 
 
Attorneys for Defendant  
FRANK MOSLEY 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
FRANK MOSLEY, 
 
 
Defendant. 
Case No: 4:23-CR-00134-AMO 
STIPULATION AND [PROPOSED] 
ORDER TO CONTINUE SENTENCING 
HEARING 
 
 
 
 
 
 
Defendant Frank Mosley, by and through his counsel of record, Malcolm 
Segal, and Assistant United States Attorney Abraham Fine, hereby stipulate and 
request that the presently set sentencing hearing date of January 22, 2024 be 
continued to March 25, 2024. This continuance is at the request of counsel for 
defendant Frank Mosley who requires additional time to assist his client in 
gathering necessary records for the meeting with the assigned Probation Officer 
and are necessary for preparation of the pre-sentence report. Counsel for 
defendant is currently scheduled for a complex and lengthy trial of a criminal case 
in Riverside County. 
Case 4:23-cr-00134-AMO     Document 41     Filed 10/02/23     Page 1 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
IT IS SO STIPULATED. 
 
Dated:  October 2, 2023.  
 
 
SEGAL & ASSOCIATES, PC 
 
 
By: 
/s/ Malcolm Segal____________ 
MALCOLM SEGAL 
 
 
Counsel for Defendant 
FRANK MOSLEY 
 
 
Dated:  October 2, 2023.  
 
 
ISMAIL J. RAMSEY 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
 
By:  /s/ Abraham Fine____________ 
 
 
 
 
 
 
 
ABRAHAM FINE 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
Case 4:23-cr-00134-AMO     Document 41     Filed 10/02/23     Page 2 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
[PROPOSED] ORDER 
 
The January 22, 2024 sentencing hearing date in the above-captioned case 
is hereby continued to March 25, 2024, at 2:00 p.m. for Defendant Frank Mosley. 
 
IT IS SO ORDERED. 
 
 
Dated: ____________, 2023.  
_________________________________ 
HON. ARACELI MARTÍNEZ-OLGUÍN 
 
 
Case 4:23-cr-00134-AMO     Document 41     Filed 10/02/23     Page 3 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
CERTIFICATE OF SERVICE 
 
I hereby certify that I caused the foregoing to be served via electronic mail 
to: 
 
 
 
 
Melissa Moy 
United States Probation Office 
450 Golden Gate Avenue 
Suite 17-6884 
San Francisco, CA  94102 
Melissa_Moy@canp.uscourts.gov 
 
on this 2nd day of October, 2023. 
 
 
 
 
 
 
 
 
/s/ Mindy Lybbert_______ 
 
 
 
 
 
 
Mindy Lybbert 
 
 
 
 
 
 
Assistant 
Case 4:23-cr-00134-AMO     Document 41     Filed 10/02/23     Page 4 of 4

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