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United States v. Vasquez

October 14, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
BALTAZAR VASQUEZ, DEFENDANT.



STIPULATION AND (PROPOSED) ORDER

STIPULATION

This matter is currently scheduled for a Motion Hearing on Monday, November 9, 2009, at 8:30 a.m., in the courtroom of the Honorable William B. Shubb. I have contacted counsel for the United States, AUSA Michael Beckwith, and we have agreed, subject to the court's approval, to augment the briefing schedule and reset the Motion Hearing from November 9, 2009 to November 23, 2009, at 8:30 a.m.

I have taken substantial steps to conclude preparing a motion for filing with the court on this case including meeting with Mr. Beckwith. We have determined that it is necessary to augment the briefing schedule established on September 28, 2009. Not only does the proposed motion require the further investigation and case research than can be accomplished in the original time frame, there has also been significant movement toward possible resolution.

Therefore, Mr. Beckwith and I have agreed to propose the following augmented briefing schedule:

1) Motion to be filed no later than 10/23/2009

2) Government's opposition to be filed no later than 11/10/2009

3) Defendant's reply to be filed no later than 11/17/2009

4) Motion Hearing set for 11/23/2009.

The parties have further stipulated that the time period from the date of the last status conference, September 28, 2009, through and including the date of the new Motion Hearing on November 23, 2009, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(7)(B)(iv).

DATED: 10/13/2009

C. EMMETT MAHLE Attorney for Defendant

BALTAZAR VASQUEZ

DATED: 10/13/2009

MICHAEL BECKWITH Assistant ...


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