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United States v. Ross

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


July 20, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOHNNIE EARL ROSS, DEFENDANT.

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

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: August 21, 2009 Time: 9:00 a.m. Judge: Garland E. Burrell, Jr.

It is hereby stipulated between the parties, Todd Leras, Assistant United States Attorney, attorney for plaintiff, and Mary M. French, Supervising Assistant Federal Defender, attorney for defendant JOHNNIE EARL ROSS, that the Status Conference hearing date of June 26, 2009, be vacated and a new Status Conference hearing date of August 21, 2009, at 9:00 a.m. be set.

This continuance is requested because defense counsel is leaving the Federal Defender's Office and Assistant Federal Defender Douglas Beevers will be taking over the case. Mr. Beevers will be transferring to Sacramento from the Fresno office effective August 3, 2009, and will need time to review the file, discuss the matter with the government, and visit with Mr. Ross at the Butte Co. Jail.

Defense counsel apologizes to the Court for the late filing of this stipulation. A continuance had been requested prior to the June 26, 2009, hearing date but counsel inadvertently neglected to file the stipulation.

It is further stipulated that the period from June 26, 2009, through and including August 21, 2009, should be excluded pursuant to 18 U.S.C. §3161(h)(7)(B)(iv) and Local Code T4 based upon continuity of counsel and defense preparation.

Dated: July 16, 2009

Respectfully submitted,

DANIEL J. BRODERICK Federal Defender

MARY M. FRENCH Supervising Assistant Federal Defender Attorney for Defendant JOHNNIE EARL ROSS

Dated: July 16, 2009

LAWRENCE G. BROWN Acting United States Attorney

Mary M. French for Todd Leras

TODD LERAS Assistant U.S. Attorney ORDER per telephonic authorization

IT IS SO ORDERED.

20090720

© 1992-2009 VersusLaw Inc.



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