Stipulation and [Proposed] Order to Continue Sentencing Hearing — USA v. Frank Mosley (N.D. Cal., Doc. 64)

Summary

A Stipulation and [Proposed] Order to Continue Sentencing Hearing, filed in the U.S. District Court for the Northern District of California, Oakland Division, on January 19, 2024 as Document 64 in United States of America v. Frank Mosley, Case No. 4:23-CR-00134-AMO, before Hon. Araceli Martínez-Olguín. Frank Mosley, through counsel Malcolm Segal of Segal & Associates, PC, and Assistant United States Attorney Abraham Fine stipulate and ask that the sentencing hearing set for March 25, 2024 be continued to May 6, 2024. The stipulation says defense counsel needs more time to help the defendant gather records for his meeting with the assigned Probation Officer. The proposed order would continue the sentencing hearing to May 6, 2024 at 2:00 p.m.

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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 
 
Date:   March 25, 2024 
Time:   2:00 pm 
Judge: Hon. Araceli Martίnez-Olguίn  
 
 
 
 
 
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 March 25, 2024, be 
continued to May 6, 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.  
Case 4:23-cr-00134-AMO     Document 64     Filed 01/19/24     Page 1 of 3

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
IT IS SO STIPULATED. 
 
Dated:  January 19, 2024. 
 
 
SEGAL & ASSOCIATES, PC 
 
 
By: 
/s/ Malcolm Segal____________ 
MALCOLM SEGAL 
 
 
Counsel for Defendant 
FRANK MOSLEY 
 
 
Dated:  January 19, 2024. 
 
 
ISMAIL J. RAMSEY 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
 
By:  /s/ Abraham Fine____________ 
 
 
 
 
 
 
 
ABRAHAM FINE 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
Case 4:23-cr-00134-AMO     Document 64     Filed 01/19/24     Page 2 of 3

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING HEARING   
 
[PROPOSED] ORDER 
 
The March 25, 2024 sentencing hearing date in the above-captioned case 
is hereby continued to May 6, 2024, at 2:00 p.m. for Defendant Frank Mosley. 
 
IT IS SO ORDERED. 
 
 
Dated: ____________, 2024.  
_________________________________ 
HON. ARACELI MARTÍNEZ-OLGUÍN 
 
 
January 19
Case 4:23-cr-00134-AMO     Document 64     Filed 01/19/24     Page 3 of 3

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