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United States v. Salinas

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


April 27, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
DANIEL SALINAS, DEFENDANT.

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

REQUEST FOR MODIFICATIN OF COURT SCHEDULE; ORDER Date: April 29, 2010 Time: 12:30pm Honorable Oliver W. Wanger

Counsel for defendant Daniel Salinas submits the following request to modify the court's schedule in the trial of this matter as follows, and for the reasons set forth below.

It is the defense's request that the trial in this matter which is set to commence on April 29, 2010, at 9:00 am, be convened, instead, at 12:30 pm to allow defense counsel to appear in Tulare County Superior Court to argue a motion to dismiss, that is scheduled to be heard at 8:30 that morning, before the Honorable Joseph Kalashian. The case, entitled People of the State of California v. Ryann Jones (VCF219203), is a first degree murder prosecution in which the People have alleged special circumstances and have announced their intention to seek the death penalty. Defense counsel substituted in as counsel of record for the defendant approximately three weeks ago, and this motion was filed by prior counsel and is ready for hearing. If successful, it would result in the dismissal of the Information in its entirety. The hearing before ted with pdfFactory trial version www.pdffactory.com

Judge Kalashian should conclude no later than 9:30 and counsel could be in court, ready to begin jury selection no later than 11:00.

I certainly realize that I am requesting an extraordinary courtesy from the court, and I would not be making this request except for the extremely serious nature of the Jones case and the importance of the pending motion.

ORDER:

Upon the application of counsel and good cause appearing therefore, it is hereby Ordered that the trial in this matter currently set to commence on April 29, 2010 at 9:00 am shall commence, instead at 12:30 pm on that same date.

20100427

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