Amended Stipulation to Continue Sentencing Hearings; Findings and Order — No. 2:24-cr-00099 (Dkt. 16, E.D. Cal.)

Summary

An amended stipulation to continue sentencing hearings, with the court's findings and order, in United States v. Jason Toland, Case No. 2:24-CR-0099-DAD, in the U.S. District Court for the Eastern District of California, filed August 28, 2024 as Document 16. It states that the government filed an Information on May 1, 2024 and that on May 13, 2024 Toland waived indictment and pleaded guilty to one count under 18 U.S.C. § 287, False Claims Against the United States. The parties ask to move sentencing from October 8, 2024 to November 5, 2024 because the probation interview did not occur until August 16, 2024, and the government does not object. The order, dated August 27, 2024 and signed by Judge Dale A. Drozd, continues the hearing to November 5, 2024 at 9:30 a.m.

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“Amended Stipulation to Continue Sentencing Hearings; Findings and Order — No. 2:24-cr-00099 (Dkt. 16, E.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/amended-stipulation-to-continue-sentencing-hearings-findings-and-order-587bf53638/, SHA-256 d3f266851b34a566a238d5b418b6de7b1726cff96e61c0ea80e8d0d35ff542b6.

Full text

                 Case 2:24-cr-00099-DAD Document 16 Filed 08/28/24 Page 1 of 3


 1   CANDICE L. FIELDS
     CANDICE FIELDS LAW, PC
 2   400 Capitol Mall, Suite 1620
     Sacramento, CA 95814
 3   Tel: (916) 414-8050
     Fax: (916) 790-9450
 4   Email: cfields@candicefieldslaw.com
 5
 6   Attorney for Defendant
     Jason Toland
 7
 8                                    UNITED STATES DISTRICT COURT

 9                                   EASTERN DISTRICT OF CALIFORNIA

10
11
     UNITED STATES OF AMERICA,                             Case No. 2:24-CR-0099-DAD
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                    Plaintiff,
13                                                         AMENDED STIPULATION TO CONTINUE
          v.                                               SENTENCING HEARINGS; FINDINGS AND
14                                                         ORDER
     JASON TOLAND
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                    Defendant.
16                                                         DATE: October 8, 2024
                                                           TIME: 9:30 a.m.
17                                                         COURT: Hon. Dale A. Drozd
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                                                      STIPULATION
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            1.       By previous order, this matter was set for sentencing hearing on October 8, 2024.
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            2.       By this stipulation, the defendant now moves to continue his sentencing hearing until
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     November 5, 2024.
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            3.       The parties agree and stipulate, and request that the Court find the following:
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                     a)     On May 1, 2024, the government filed an Information against defendant. ECF
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            No. 1. On May 13, 2024, the defendant waived Indictment and entered a guilty plea to a single
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            count of Violation of 18 U.S.C. § 287 – False Claims Against the United States.
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                     b)     Due to delays in scheduling defendant’s probation interview (attributable to both
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            the probation officer’s, defense counsel’s, and defendant’s respective schedules), defendant’s
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                                  STIPULATION TO CONTINUE SENTENCING HEARING
                Case 2:24-cr-00099-DAD Document 16 Filed 08/28/24 Page 2 of 3


 1            probation interview did not occur until August 16, 2024. Pursuant to Federal Rule of Criminal

 2            Procedure 32, the probation officer and counsel, respectively, require time to draft and respond

 3            to the presentence report, and to gather documents for use in drafting the presentence report.

 4                   c)      The government does not object to the continuance.

 5                   d)      Based on the above-stated findings, good cause exists to continue defendant’s

 6            sentencing hearing in this matter from October 8, 2024, to November 5, 2024.

 7                   e)      This is the first request for continuance of sentencing.

 8                   f)      The parties request the following modified disclosure schedule:

 9                           Draft PSR: September 24, 2024
                             Informal Objections: October 1, 2024
10                           Final PSR: October 15, 2024
                             Corrections: October 22, 2024
11                           Replies/Briefs: October 29, 2024

12            IT IS SO STIPULATED.

13    Dated: August 26, 2024                                  PHILLIP A. TALBERT
                                                              UNITED STATES ATTORNEY
14
15                                                            /s/ Denise Yasinow
                                                              Denise Yasinow
16                                                            Assistant United States Attorney

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18    Dated: August 26, 2024                                  /s/ Candice L. Fields
                                                              Candice L. Fields
19                                                            Counsel for Defendant
                                                              Jason Toland
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                                             FINDINGS AND ORDER
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              Pursuant to the stipulation of the parties and good cause appearing, the sentencing hearing of
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     defendant Toland is hereby continued to November 5, 2024 at 9:30 a.m.
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              IT IS SO ORDERED.
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     Dated:     August 27, 2024
27                                                       DALE A. DROZD
28                                                       UNITED STATES DISTRICT JUDGE

                                   STIPULATION TO CONTINUE SENTENCING HEARING
     Case 2:24-cr-00099-DAD Document 16 Filed 08/28/24 Page 3 of 3


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                   STIPULATION TO CONTINUE SENTENCING HEARING

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