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United States v. Angeles

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


March 16, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JAIME ANGELES ET. AL., DEFENDANTS.

STIPULATION AND (PROPOSED) ORDER

STIPULATION

This matter is scheduled for Trial Confirmation Conference on March 20, 2009, at 9:00 a.m., in the courtroom of the Honorable Garland E. Burrell, Jr. I have contacted counsel for all defendants, and counsel for the United States, AUSA Heiko Coppola, and AUSA Phil Talbert, and they have all agreed, subject to the court's approval, to continue this matter until April 3, 2009, at 9:00 a.m. It is anticipated that the jury trial that is currently set for April 20, 2009, will be vacated, and reset for a later date.

All counsel have received approximately 9,000 pages of discovery in the above matter, and continue to review, organize and prepare these materials. All counsel are also reviewing these materials for the potential preparation of motions. Investigation is continuing.

All parties hereby agree and stipulate to a continuance of the Trial Confirmation Conference that was scheduled for March 20, 2009, at 9:00 a.m., to April 3, 2009, at 9:00 a.m. in the courtroom of the Honorable Garland E. Burrell, Jr. They further stipulate to the exclusion of time through that date pursuant to Local Code T-2, as the matter is complex, and Local Code T-4, as the above continuance is necessary for preparation of counsel.

(PROPOSED) ORDER

GOOD CAUSE APPEARING, and by stipulation of all counsel, the Status Conference that was scheduled for March 20, 2009, at 9:00 a.m., is hereby continued to April 3, 2009, at 9:00 a.m., in the courtroom of the Honorable Garland E. Burrell, Jr. Time is excluded through that date pursuant to Local Codes T-2, due to complexity, and T-4 for preparation of counsel.

20090316

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