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Stipulation and Proposed Order to Continue Sentencing Hearing — United States v. Gurjeet Bath (Dkt. 34)

Summary

Document 34 in United States of America v. Gurjeet Bath, Case No. 1:24-cr-00198-JLT-SKO, is a Stipulation and [Proposed] Order to Continue Sentencing Hearing filed January 9, 2026, in the U.S. District Court for the Eastern District of California. The stipulation recites that the Defendant has circulated proof of payment to the SBA by way of cancelled/deposited checks, and that the SBA has confirmed to the Government that full restitution has been paid. It states that Defendant's counsel needs the opportunity to respond to the Final PSR and submit a sentencing brief. The parties stipulate to continue the January 26, 2026 sentencing to March 23, 2026, or to a date convenient to the Court. The order page is dated January 9, 2026.

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“Stipulation and Proposed Order to Continue Sentencing Hearing — United States v. Gurjeet Bath (Dkt. 34).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-caed-451006-34-0-ab8335a474/, SHA-256 f6a4a837381224bcca87f4b478354b5779ebadfe43b735b32519a920ba7b5cee.

Full text

     Case 1:24-cr-00198-JLT-SKO             Document 34     Filed 01/09/26      Page 1 of 3
                                                                  (SPACE BELOW FOR FILING STAMP ONLY)
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      Roger S. Bonakdar, #253920
 3    2344 TULARE ST., SUITE 200
      FRESNO, CALIFORNIA 93721
 4    PHONE (559) 495-1545
      FAX (559) 495-1527
 5    Attorney for DEFENDANT, GURJEET BATH
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                               IN THE UNITED STATES DISTRICT COURT
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                                  EASTERN DISTRICT OF CALIFORNIA
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      UNITED STATES OF AMERICA,                           CASE NO. 1:24-CR-00198-001
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                                     Plaintiff,           STIPULATION AND [PROPOSED]
10                                                        ORDER TO CONTINUE SENTENCING
                               v.                         HEARING
11
      GURJEET BATH,                                       Sentencing: January 26, 2026
12                                   Defendant.
13

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              DEFENDANT, GURJEET BATH’s Sentencing Hearing is currently scheduled for
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      January 26, 2026. The parties request a continuance of Sentencing in this matter, so that matters
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      related to restitution can be investigated and addressed, prior to sentencing.
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              WHEREAS this matter is a PPP fraud case, where the dollar loss and the fact of
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      restitution are dispositive issues.
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              WHEREAS Defendant has circulated proof of payment to the SBA by way of
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      cancelled/deposited checks to the Government, over a month ago. The Government made every
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      effort to confirm the fact of payments, via the SBA, and the parties worked together to get this
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      verified.
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              WHEREAS the PSR has been prepared without reference for or consideration of
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      restitution having been paid in full.
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              WHEREAS only today the SBA has confirmed to the Government that full restitution
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      has been paid.
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                                                 1
                       STIPULATION AND ORDER TO CONTINUE SENTENCING HEARING
     Case 1:24-cr-00198-JLT-SKO          Document 34         Filed 01/09/26      Page 2 of 3
 1           WHEREAS the fact that restitution has been paid in full is dispositive as to sentencing,

 2    and needs to be considered by Probation and addressed by the Defense in informal objections

 3    and the interactive process attendant to the final PSR and recommendations for a variance or

 4    departure from sentencing guidelines.

 5           WHEREAS Defendant’s counsel needs to be afforded opportunity to respond to the

 6    Final PSR (after the interactive process of informal and formal objections), and submit a

 7    sentencing brief; this is not practicable with the Sentencing as currently set.

 8           WHEREAS in light of the above, request is made for a continuance of the January 26,

 9    2026, Sentencing hearing for a period of 60 days.

10           WHEREAS the Parties request a renewed Sentencing Referral Schedule be issued,

11    based on the continued sentencing date, for any informal and formal objections and sentencing

12    brief due dates.

13           WHEREAS it is understood that the Defense does not intend to request any further

14    continuances of sentencing attendant to this restitution issue, or otherwise without new or

15    otherwise good cause.

16           THEREFORE, IT IS STIPULATED by and between the Parties that the January 26,

17    2026, Sentencing hearing be continued to March 23, 2026, or to a date convenient to the Court.

18           IT IS SO STIPULATED:
      Dated: January 8, 2026                                ERIC GRANT
19                                                          United States Attorney
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21                                                     By: /s/ Joseph Barton
                                                           JOSEPH BARTON
22                                                         Assistant United States Attorney

23    Dated: January 8, 2026                                BONAKDAR LAW FIRM

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                                                        By: /s/ Roger S. Bonakdar
25                                                          ROGER S. BONAKDAR
                                                            Attorney for Defendant
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                                                            GURJEET BATH
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                                       [Order Continues on Next Page]
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                    STIPULATION AND ORDER TO CONTINUE SENTENCING HEARING
     Case 1:24-cr-00198-JLT-SKO         Document 34        Filed 01/09/26      Page 3 of 3
 1                                                ORDER

 2           Upon the Parties’ stipulation and for good cause shown, Defendant, GURJEET BATH’s

 3    Sentencing Hearing is continued from January 26, 2026, to March 23, 2026, at 9:00 a.m. The

 4    Clerk shall issue a new schedule for informal and formal objections and sentencing briefs to be

 5    due, based on the continued sentencing date.

 6           All orders not expressly modified by this order remain in full force and effect.

 7    IT IS SO ORDERED.
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         Dated:     January 9, 2026
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                    STIPULATION AND ORDER TO CONTINUE SENTENCING HEARING


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