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United States v. Pulido-Valencia

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


February 19, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOSE MANUEL PULIDO-VALENCIA, DEFENDANTS.

The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge

STIPULATION AND ORDER CONTINUING STATUS CONFERENCE

IT IS HEREBY stipulated between the parties, Plaintiff United States of America, by and through Assistant United States Attorney Daniel McConkie, and Defendant, Jose Manuel PulidoValencia, by and through his attorney, Lorie J. Teichert, that the previously set Status Conference of February 19, 2009 at 2:00 p.m. be continued to April 2, 2009 at 9:00 a.m.

The continuance is requested because Defendant's attorney is conducting defense investigation relating to the Defendant's criminal history and is awaiting the production of copies of multiple state court files from two jurisdictions so that she may conduct further research and investigation into the veracity of the Defendant's prior convictions and the criminal history points ascribed to these priors.

It is further stipulated and agreed between the parties that the period from February 19, 2009 through and including April 2, 2009, should be excluded in computing the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act for the purpose of defense preparation and investigation. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the Defendant in a speedy trial. As such, this is an appropriate exclusion of time under the Speedy Trial Act within the meaning of Title 18, United States Code, section 3161(h)(7)(A) and (B)(iv), and Local Code T4.

Dated: February 17, 2009

Respectfully submitted,

LORIE J. TEICHERT Attorney for Defendant JOSE MANUEL PULIDO-VALENCIA

LAWRENCE BROWN Acting United States Attorney

By: Lorie J. Teichert for Daniel McConkie per telephonic authorization

DANIEL MCCONKIE Assistant U.S. Attorney

20090219

© 1992-2009 VersusLaw Inc.



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