Case 3:16-cr-00051-BR

Document 1354

Filed 09/27/16

Page 1 of 1

Benjamin T. Andersen
101 SW Madison #9068
Portland, Oregon 97207
t. 503.860.2531
bta@btandersen.com
Attorney for Defendant
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
Geoffrey STANEK,

Case No. 3:16-CR-051-BR-23

DECLARATION IN SUPPORT OF
MOTION TO CONTINUE/RESET
TRIAL DATE

Defendant.
I, Benjamin Andersen, declare:
1.

I am Mr. Staneks attorney. Mr. Stanek previously pleaded guilty to Count One of the

Superseding Indictment; a sentencing hearing is presently set for October 7th, 2016.
2.

I am still in the process of acquiring documentation to aid in the sentencing

determination. I am requesting a setover of at least one month in order to complete this

acquisition of documents and other preparations for the sentencing hearing.
3.

Mr. Stanek is out of custody and is in full compliance with the conditions of his

pretrial release.
4.

AUSA Craig Gabriel, on behalf of the government, does not oppose this motion.
Respectfully submitted and dated this 27th day of September 2016.
/s/ (intended as original in electronic filings)
_______________________________________
Benjamin T. Andersen, OSB 06256

PAGE 1 DECLARATION IN SUPPORT OF MOTION TO CONTINUE/RESET SENTENCING DATE

United States v. STANEK,
USDC Oregon Case No. 3:16-CR-051-BR-23