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United States v. Martinez-Martinez

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


August 26, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
TERESA MARTINEZ-MARTINEZ, DEFENDANT.

The opinion of the court was delivered by: Oliver W. Wanger United States District Judge

STIPULATION TO VACATE EXISTING TRIAL SCHEDULE AND TRIAL DATE AND SETTING HEARING TO ESTABLISH NEW MOTIONS AND TRIAL SCHEDULE; ORDER

Date: August 31, 2009 Time: 9:00 A.M. Court: Hon. Oliver W. Wanger

IT IS HEREBY STIPULATED by and between the parties hereto, through their respective counsel of record herein, that the existing trial schedule in the above-referenced matter may be vacated, and that a hearing may be set for August 31, 2009, at 9:00 A.M. to establish a new motions and trial schedule.

This stipulation is made to allow the defense additional time for investigation and plea negotiation prior to trial and possibly negate the necessity of trial. Defense counsel was assigned the above referenced matter when a trial date was already set. Defense counsel has not had an adequate opportunity to file necessary motions, investigate and prepare for trial. The request to vacate the existing trial date and set a hearing to establish a new motions and trial schedule will conserve time and resources for the parties and the court.

The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice herein and for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(1)(F), 3161(h)(8)(A) and 3161(h)(8)(B)(i) and (iv).

LAWRENCE G. BROWN United States Attorney

DATED: August 25, 2009

ELANA LANDAU Assistant United States Attorney Attorney for Plaintiff

DANIEL J. BRODERICK Federal Defender

DATED: August 25, 2009

MARC DAYS Assistant Federal Defender Attorney for Defendant TERESA MARTINEZ-MARTINEZ

ORDER

IT IS SO ORDERED.

20090826

© 1992-2009 VersusLaw Inc.



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