Stipulation and Proposed Order to Continue Sentencing Hearing — United States v. Cassie Will-Darnall (Dkt. 64)

Summary

Document 64 in United States of America v. Cassie Will-Darnall, Case 5:24-cr-00292-PCP (N.D. Cal., San Jose Division), is a Stipulation and [Proposed] Order to Continue Sentencing Hearing filed June 4, 2025. The stipulation, dated June 3, 2025, asks the Court to continue the hearing set for June 11, 2025, at 10:00 a.m. to September 3, 2025, at 10:00 a.m. It recites that on May 29, 2025 U.S. Probation disclosed the final Presentence Report, and that the defense requests time to investigate further a Sentencing Guidelines enhancement found by Probation that will affect the applicable guideline range. The signature block lists Varell L. Fuller and, for United States Attorney Craig H. Missakian, Johnny James, Special Assistant United States Attorney, each with /s/. The order's date line reads June 4, 2025 above The Honorable P. Casey Pitts.

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Full text

            Case 5:24-cr-00292-PCP         Document 64         Filed 06/04/25     Page 1 of 2



 1   JODI LINKER, Bar No. 230273
     Federal Public Defender
 2   Northern District of California
     VARELL L FULLER, Bar No. 202680
 3   Assistant Federal Public Defender
     55 South Market Street, Suite 820
 4
     San Jose, CA 95113
 5   Telephone: (408) 291-7753
     Facsimile: (408) 291-7399
 6   Email:       Varell_Fuller@fd.org

 7
     Counsel for Defendant WILL-DARNALL
 8

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                                   IN THE UNITED STATES DISTRICT COURT
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                             FOR THE NORTHERN DISTRICT OF CALIFORNIA
11
                                             SAN JOSE DIVISION
12

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      UNITED STATES OF AMERICA,                             Case No. CR 24–00292 PCP
14
                      Plaintiff,                            STIPULATION AND [PROPOSED]
15                                                          ORDER TO CONTINUE SENTENCING
              v.                                            HEARING
16
      CASSIE WILL-DARNALL,
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                      Defendant.
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19                                             STIPULATION

20         The parties, by and through their respective counsel, hereby stipulate, subject to the Court’s

21   approval, that the sentencing hearing currently set for June 11, 2025, at 10:00 a.m., shall be continued

22   to September 3, 2025, at 10:00 a.m. On May 29, 2025, U.S. Probation disclosed the final Presentence

23   Report in this matter. ECF. Dkt. No. 59. The defense respectfully requests the Court continue the

24   current sentencing hearing date to permit the defense additional time to investigate further a

25   Sentencing Guidelines enhancement found by Probation that will affect Mr. Will-Darnall’s applicable

26   guideline range. Furthermore, the defense needs additional time to prepare for Ms. Will-Darnall’s

27   sentencing hearing. Specifically, defense counsel is researching further mitigation arguments that the

28   defense intends to present at the upcoming sentencing hearing. The parties and Probation respectfully

     STIPULATION AND [PROPOSED] ORDER
     WILL-DARNALL, CR 24–00292 PCP
                                                        1
            Case 5:24-cr-00292-PCP          Document 64       Filed 06/04/25      Page 2 of 2



 1   request the date of September 3, 2025, as that date accommodates the parties and the assigned
 2   Probation Officer’s respective availability.
 3         For the reasons set forth above, the parties stipulate and agree to continue the sentencing
 4   hearing from June 11, 2025, to September 3, 2025.
 5         IT IS SO STIPULATED.
 6    Dated: June 3, 2025                                JODI LINKER
 7                                                       Federal Public Defender
                                                         ____________/s/_______________
 8                                                       VARELL L. FULLER
                                                         Assistant Federal Public Defender
 9

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      Dated: June 3, 2025                                CRAIG H. MISSAKIAN
11                                                       United States Attorney
                                                         ___________/s/________________
12                                                       JOHNNY JAMES
                                                         Special Assistant United States Attorney
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14                                          [PROPOSED] ORDER
15         GOOD CAUSE APPEARING, upon stipulation of the parties, IT IS HEREBY ORDERED that
16   the sentencing hearing currently set for June 11, 2025, at 10:00 a.m., shall be continued to September
17   3, 2025, at 10:00 a.m.
18         IT IS SO ORDERED.
19         Dated: June 4, 2025
                 ___________________
                                                         ___________________________________
20
                                                         THE HONORABLE P. CASEY PITTS
21                                                       United States District Judge

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     STIPULATION AND [PROPOSED] ORDER
     WILL-DARNALL, CR 24–00292 PCP
                                                        2


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