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United States v. Valencia

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


April 23, 2009

UNITED STATES OF AMERICA PLAINTIFF,
v.
MIGUEL VALENCIA, ET. AL., DEFENDANTS.

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

STIPULATION AND [PROPOSED] ORDER CONTINING STATUS CONFERENCE AND EXCLUDING TIME

It is hereby stipulated and agreed to between the United States of America through Heiko Coppola, Assistant United States Attorney, and defendant, Juan Jose Sanchez Valencia, by and through his counsel, Lindsay Anne Weston, defendant Daniel Chavez, by his counsel, John R. Manning, defendant Miguel Valencia, by his counsel, Matthew Bockman, defendant Ricardo Galindo, by his counsel, Timothy Warriner, Martin Magana Ramos, by his counsel, Fred Dawson, and Rayez Espinoza Aguilar, by his counsel, Dan Koukol, that the status conference in this matter currently scheduled for April 24, 2009, at 9:00 a.m. be continued to May 29, 2009, at 9:00 a.m.

The basis for this continuance is that defense counsel requests additional time to review a large amount of discovery recently provided by the government and, further, certain counsel are engaged in plea negotiations with the government and request time to consult with their clients.

IT IS FURTHER STIPULATED that the period from April 24, 2009, (the date currently set for the status conference) through and including May 29, 2009, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) and Local Code T4 for continuity and preparation of counsel. Undersigned counsel Weston has written authority from all of the parties, including the government, to sign their name to this Stipulation and Proposed Order.

Dated: April 21, 2009

Respectfully submitted,

Lindsay Anne Weston Attorney for Defendant JUAN JOSE SANCHEZ VALENCIA

John R. Manning Attorney for Defendant DANIEL CHAVEZ

Matthew Bockman Attorney for Defendant MIGUEL VALENCIA

Timothy Warriner Attorney for Defendant RICARDO DIAZ GALINDO

Fred N. Dawson Attorney for Defendant MARTIN MAGANA RAMOS

Dan Koukol Attorney for Defendant RAYEZ ESPINOZA AGUILAR

LAWRENCE G. BROWN Acting United States Attorney

Heiko Coppola Assistant United States Attorney Per telephonic and written authorization

ORDER

IT IS SO ORDRED.

20090423

© 1992-2009 VersusLaw Inc.



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