2:22-cr-00058•USA v. Lawson et al
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-1- 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 United States v. Lawson, 2:22CR58-DJC-1 Stipulation and Order to Continue Judgment and Sentencing HEATHER E. WILLIAMS, SBN 122664 Federal Defender HOOTAN BAIGMOHAMMADI, SBN 279105 Assistant Federal Defender Designated Counsel for Service 801 I Street, Third Floor Sacramento, CA 95814 T: (916) 498-5700 F: (916) 498-5710 Attorneys for Defendant Mr. Lawson IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, vs. JERRELL LAWSON, Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 2:22CR58-DJC-1 STIPULATION AND ORDER TO CONTINUE JUDGMENT AND SENTENCING Date: March 19, 2026 Time: 9:00 a.m. Judge: Daniel J. Calabretta IT IS HEREBY STIPULATED and agreed by and between United States Attorney Eric Grant, through Assistant United States Attorney Ross Pearson, counsel for Plaintiff, and Federal Defender Heather Williams, through Assistant Federal Defender Hootan Baigmohammadi, counsel for Defendant Jerrell Lawson, that the previously scheduled Judgment and Sentencing set for March 19, 2026 be continued to April 23, 2026 at 9:00 a.m. The parties specifically stipulate as follows: 1. Good cause and compelling circumstances exist to continue Sentencing. Defense counsel was preparing for trial in another case for the past month. He was unable to devote any time to the instant matter during that period. The trial was set to commence on February 2, 2026. Despite being unexpectedly relieved as counsel in the other matter today, defense counsel still needs additional time to adequately prepare for Sentencing in the instant matter. Case 2:22-cr-00058-DJC Document 389 Filed 01/29/26 Page 1 of 3
-2- 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 United States v. Lawson, 2:22CR58-DJC-1 Stipulation and Order to Continue Judgment and Sentencing 2. The government does not object to Mr. Lawson’s continuance request. 3. For the forgoing reasons, the parties jointly request that the Judgment and Sentencing Schedule be modified as follows. U.S. Probation has been consulted and is available. Draft PSR March 12, 2026 Informal Objections March 26, 2026 Final PSR April 2, 2026 Formal Objections April 9, 2026 Response to Formal Objections April 16, 2026 Judgment and Sentencing April 23, 2026 Respectfully submitted, HEATHER E. WILLIAMS Federal Defender Date: January 27, 2026 /s/ Hootan Baigmohammadi HOOTAN BAIGMOHAMMADI Assistant Federal Defender Attorneys for Defendant Mr. Lawson Date: January 27, 2026 ERIC GRANT United States Attorney /s/ Ross Pearson ROSS PEARSON Assistant United States Attorney Attorneys for Plaintiff Case 2:22-cr-00058-DJC Document 389 Filed 01/29/26 Page 2 of 3
-3- 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 United States v. Lawson, 2:22CR58-DJC-1 Stipulation and Order to Continue Judgment and Sentencing O R D E R The Court, having received and considered the parties’ stipulation, and good cause appearing therefrom, adopts the parties’ stipulation in its entirety as its order. IT IS SO ORDERED. Dated: January 29, 2026 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE Case 2:22-cr-00058-DJC Document 389 Filed 01/29/26 Page 3 of 3
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