IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 30, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
MIKHAIL VOLOVNIKOV, DEFENDANT.
STIPULATION TO CONTINUE MOTION TO TERMINATE PROBATION from November 2,2009 to January 4,2010 and Proposed ORDER
WHEREFORE, upon showing of good cause, the UNITED STATES OF AMERICA, represented by JARED DOLAN, Assistant United States Attorney, and Defendant, MIKHAIL VOLOVNIKOV, represented by DANIEL V. BEHESNILIAN, do hereby stipulate to the following:
That, this matter is currently set for motion hearing on November 2, 2009 at 8:30 a.m.
That, defense counsel and counsel for the government have conferred with each other as well as the Probation Department in connection with entering into a possible stipulation for Early Termination of Probation and have decided that additional time is required to finalize those conditions which need to be met for all parties to agree and submit the motion to the Court for final decision possibly without hearing.
For this reason, the parties agree and stipulate that the Motion be continued to a date so that a final Stipulation may be submitted.
Authorization for Dated: October 29, 2009 Mr. Dolan's signature obtained via phone conversation on October 29, 2009 /s/Jared Dolan JARED DOLAN Assistant U.S. Attorney
Dated: October 29, 2009
GOOD CAUSE NOW appearing, it is hereby ordered that the hearing in this matter currently set for November 2, 2009 be continued to January 4, 2010 at 8:30 a.m. on the above date and time for the purpose of the hearing.
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