UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
v. Cr. Nos. 87-63,
Judge Charles R. Richey
MOTION TO RESCHEDULE HEARING ON DEFENDANT'S MOTION
TO RECONSIDER AND/OR SENTENCING
According to a Notice, signed by Joe Burgess and filed
on January 16, 1988, "hearing on motion for reconsideration
and/or sentencing" is scheduled for January 28, 1988. Pursuant
to Local Rule 311 defendant hereby moves the Court to reschedule
In relevent part Local Rule 311.2 provides:
As of January 24th, 1988 the presentence report in this
case had not been made available for review by the defendant.
Defendant has had no opportunity to confer with the Ms. Robinson,
the probation officer, and Ms. Robinson does not plan to be in
court for the sentencing. Public Gathering Permit with with Mr.
It may seem that the appearance of justice would best be
served only if the defendant has had a reasonable period of time
in advance of her sentencing to review, confer with the probation
officer, and submit written objections to such factual disputes
as may remain. As this matter is presently scheduled defendant
will be hard pressed to prepare for her sentencing. SEE, Local
Rule 311, generally.
Therefore defendant urges the Court to apply the twenty-seven
day standard of Local Rule 311, and to reschedule the proceedings
presently set for January 28, 1988 accordingly.
A proposed Order is attached.
"(a) Not less than 27 days prior to the date set for
the sentencing, the probation officer shall disclose the initial
presentence report to the defendant...."
CERTIFICATE OF SERVICE
I, William Thomas, hereby certify that a copy of the foregoing
Motion To Join The Motion To Reschedule Sentencing was served
upon Assistant U.S. Attorney Mark Dubester, Judiciary Square,
555 4th Street, NW, Washington, D.C., 20001, by hand on this 21st
day of January, 1988.
Ellen Thomas, Defendant,
1440 N Street, N.W. Apt. 410
Washington, D.C. 20005