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United States v. Angeles

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


April 9, 2009

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

STIPULATION AND (PROPOSED) ORDER

STIPULATION

This matter is currently scheduled for Trial Confirmation Conference on April 3, 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 December 18, 2009, at 9:00 a.m. We are also jointly requesting to vacate the jury trial that is currently set for April 21, 2009, and reset the new jury trial date for January 26, 2010, at 9:00 a.m.

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 in this case by defense counsel is continuing. Some counsel are currently in lengthy jury trials and other counsel have jury trials set in the near future. When comparing trial schedules with defense counsel and government counsel, and factoring in the investigation and trial preparation that still needs to be completed, the best date for all counsel was determined to be January 26, 2010.

All parties hereby agree and stipulate to a continuance of the Trial Confirmation Conference that was scheduled for April 3, 2009, at 9:00 a.m., to December 18, 2009, at 9:00 a.m. in the courtroom of the Honorable Garland E. Burrell, Jr. All parties hereby agree and stipulate to a continuance of the jury trial from April 21, 2009, to January 26, 2010. All parties further stipulate to the exclusion of time through January 26, 2010, 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 Trial Confirmation Conference that was scheduled for April 3, 2009, at 9:00 a.m., is hereby continued to December 18, 2009, at 9:00 a.m., in the courtroom of the Honorable Garland E. Burrell, Jr. The jury trial that was scheduled for April 21, 2009, is hereby continued to January 26, 2010, at 9:00 a.m. Time is excluded through January 26, 2010, pursuant to Local Codes T-2, due to complexity, and T-4 for preparation of counsel.

20090409

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