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United States of America v. Plaintiff

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


December 7, 2010

UNITED STATES OF AMERICA,
v.
PLAINTIFF, WENDALL STEWART, ET AL, DEFENDANTS.

The opinion of the court was delivered by: Judge: Honorable Garland E. Burrell, Jr.

STIPULATION AND [PROPOSED ORDER] CONTINUING STATUS CONFERENCE

IT IS HEREBY stipulated between the United States of America through its undersigned

counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Ricardo Venegas, John R. Manning, Esq., counsel for defendant Wendell Stewart, Candace A. Fry, Esq., counsel for defendant Valerie White, William E. Bonham, Esq., and counsel for defendant Isauro Jauregui Catalan, Edward C. Bell, Esq., that the status conference presently set for December 3, 2010 be continued to February 4, 2011, at 9:00 a.m., thus vacating the presently set status conference.

Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code§ 3161(h)(7)(B)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the continuance is requested to allow more time for defense preparation and possible negotiations for resolution) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference,

February 4, 2011.

IT IS SO STIPULATED.

Dated: December 1, 2010 /s/ John R. Manning JOHN R. MANNING Attorney for Defendant Ricardo Venegas

Dated: December 1, 2010 /s/ Candace A. Fry CANDACE A. FRY Attorney for Defendant Wendell Stewart

Dated: December 1, 2010 /s/ William E. Bonham WILLIAM E. BONHAM Attorney for Defendant Valerie White

Dated: December 1, 2010 /s/ Edward C. Bell EDWARD C. BELL Attorney for Defendant Isauro Jauregui Catalan

Dated: December 1, 2010 Benjamin B. Wagner United States Attorney

by: /s/ Jill M. Thomas JILL M. THOMAS Assistant U.S. Attorney

JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant RICARDO VENEGAS

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

UNITED STATES OF AMERICA, v. Plaintiff, WENDALL STEWART, et al., Defendants.

No. CR-S-06-0441 GEB ORDER TO CONTINUE STATUS CONFERNCE

GOOD CAUSE APPEARING, it is hereby ordered that the December 3, 2010 status conference be continued to February 4, 2011 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFOR IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161 (h) (7) (B) (iv) and Local Code T4 from the date of this order to February 4, 2011.

IT IS SO ORDERED.

Date: 12/6/2010

GARLAND E. BURRELL, JR. United States District Judge

DEAC_Signature-END:

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20101207

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