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United States v. Boze

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


April 3, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JEREMY THOMAS BOZE, DEFENDANT.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED] ORDER CONTINUING MOTION HEARING AND EXCLUDING TIME

Date: May 1, 2009 Time: 9:00 a.m. Judge: Hon. Garland E. Burrell, Jr.

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, HEIKO COPPOLA, Assistant United States Attorney, attorney for Plaintiff, and LINDA C. HARTER, Chief Assistant Federal Defender, attorney for Defendant, that the motions hearing date of May 1, 2009 be vacated and continued for hearing on motions to May 29, 2009 at 9:00 a.m..

Defendant's motions will be due no later than April 24, 2009; any government opposition due no later than May 15, 2009.

This continuance is requested as the parties will be using this period of time to work out some issues short of litigation.

Based upon the foregoing, the parties agree that the time under the Speedy Trial Act should be excluded from the date of signing of this order through and including May 29, 2009 pursuant to 18 U.S.C. §3161 (h)(8)(B)(iv) [reasonable time to prepare] and Local Code T4 based upon continuity of counsel and defense preparation.

Dated: March 27, 2009

Respectfully submitted,

DANIEL J. BRODERICK Federal Public Defender

LINDA C. HARTER Chief Assistant Federal Defender Attorney for Defendant JEREMEY BOZE

Dated: March 27, 20098

LARRY BROWN Acting United States Attorney

HEIKO COPPOLA Assistant U.S. Attorney Attorney for Plaintiff

ORDER

IT IS SO ORDERED. Time is excluded from today's date through and including May 29, 2009 in the interest of justice pursuant to 18 U.S.C. §3161(h)(8)(B)(iv)[reasonable time to prepare] and Local Code T4.

20090403

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