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United States v. Cervantes

October 8, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
ELY CERVANTES, DEFENDANT.



The opinion of the court was delivered by: Judge Hon. Oliver W. Wanger

Date: November 9, 2009

STIPULATION TO CONTINUE STATUS CONFERENCE; MODIFY BRIEFING SCHEDULE; AND [PROPOSED] ORDER THEREON

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, KIMBERLY A. SANCHEZ, Assistant United States Attorney, and ERIC V. KERSTEN, Assistant Federal Defender, counsel for Defendant Ely Cervantes, that the date for status conference may be continued to November 9, 2009, or the soonest date thereafter that is convenient to the court. The date currently set for status conference is October 13, 2009. The requested new date is November 9, 2009.

The parties are exploring the possibility of resolving this matter with a negotiated settlement, in lieu of litigating the pending suppression motion. This continuance is requested to allow additional time to attempt to resolve the matter.

The parties agree that the delay resulting from the continuance shall be excluded as necessary for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), and for the filing of pretrial motions and ruling thereon pursuant to 18 U.S.C. § 3161(h)(1)(D).

LAWRENCE G. BROWN Acting United States Attorney

DATED: October 7, 2009

By KIMBERLY A. SANCHEZ Assistant United States Attorney Attorney for Plaintiff

DANIEL J. BRODERICK Federal Defender

DATED: October 7, 2009

By ERIC V. KERSTEN Assistant Federal Defender Attorney for Defendant ELY CERVANTES

ORDER

IT IS SO ORDERED. The intervening period of delay is excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), and 18 U.S.C. § 3161(h)(1)(D). New ...


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