2:22-cr-00058•USA v. Lawson et al
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1 Stipulation and Proposed Order to Continue Sentencing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Etan Zaitsu [SBN 287106] Attorney-at-Law Zaitsu Law 331 J Street, Suite 200 Sacramento, CA 95814 916.542.0270 Attorney for Defendant JAMES GORDLEY IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. JAMES GORDLEY, Defendant. Case No.: 2:22-CR-00058 DJC STIPULATION AND ORDER TO CONTINUE SENTENCING The parties, defendant James Gordley through his court-appointed counsel, and the government through its counsel, hereby stipulate to and request that the sentencing date set for November 6, 2025, be continued to December 4, 2025, and that all filing due dates be moved consistent with the new sentencing date as detailed below. In support of this stipulation, the parties request that the Court find the following: 1. Mr. Gordley sat for his probation interview on August 7, 2025. 2. Probation subsequently released its Draft PSR on August 18, 2025. Neither party filed Informal Objections. Probation filed its Final PSR on September 9, 2025 3. On Sept. 15, 2025, upon stipulation and request, the Court continued sentencing to Nov. 6, 2025. At that time, defense counsel represented that he was facing certain challenges hiring experts for sentencing mitigation purposes. 4. Since then, counsel for the defendant represents that the two experts he sought to hire Case 2:22-cr-00058-DJC Document 370 Filed 11/03/25 Page 1 of 3
2 Stipulation and Proposed Order to Continue Sentencing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 have agreed to provide services despite the current inability of the government to pay for such services. However, the funding request for one of the experts—psychological services—had to be refiled a number of times. For this reason, defense counsel seeks a 1-month continuance of the sentencing hearing to December 4, 2025. 5. The government is not opposed. 6. The parties therefore request the Court approve the following sentencing schedule: Nov. 6: New Sentencing Date Oct 30: Reply Oct. 23: Formal Objections SO STIPULATED Respectfully submitted, Dated: October 31, 2025 s/ETAN ZAITSU ETAN ZAITSU Attorney for the Defendant JAMES GORDLEY Dated: October 31, 2025 ERIC GRANT United States Attorney /s/ JASON HITT JASON HITT Assistant United States Attorney Case 2:22-cr-00058-DJC Document 370 Filed 11/03/25 Page 2 of 3
3 Stipulation and Proposed Order to Continue Sentencing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ORDER For the reasons stated by the parties in the above stipulation, and good cause showing, the Defendant’s sentencing hearing scheduled November 6, 2025, is hereby continued to December 4, 2025, at 9:00A.M., with all remaining filings due dates moved consistent with the parties’ stipulated scheduled. IT IS SO FOUND AND ORDERED. Dated: October 31, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE Case 2:22-cr-00058-DJC Document 370 Filed 11/03/25 Page 3 of 3
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