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United States of America v. Eloy Chavez-Loviano

December 15, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
ELOY CHAVEZ-LOVIANO,
DEFENDANT.



The opinion of the court was delivered by: Judge: Honorable Lawrence J. O'Neill

DEFENDANT'S STIPULATION TO CONTINUE STATUS CONFERENCE HEARING AND ORDER THEREON

DATE: January 7, 2011 TIME: 9:00 a.m.

IT IS HEREBY STIPULATED by and between the parties through their respective counsel, Assistant United States Attorney Susan Phan, Counsel for Plaintiff, and Assistant Federal Defender Victor M. Chavez, Counsel for Defendant Eloy Chavez-Loviano, that the hearing currently set for December 17, 2010 may be rescheduled to January 7, 2011 at 9:00 a.m.

The defense proposes this stipulation is to allow defendant additional time to consider the government's offer and to discuss it with his family. The requested continuance will conserve time and resources for both counsel and the court.

The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice herein and for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).

BENJAMIN B. WAGNER United States Attorney

Dated: December 15, 2010

/s/ Susan Phan SUSAN PHAN Assistant United States Attorney Attorney for Plaintiff

DANIEL J. BRODERICK Federal Defender

Dated: December 15, 2010

/s/ Victor M. Chavez VICTOR M. CHAVEZ Assistant Federal Defender Attorneys for Defendant Eloy Chavez-Loviano

ORDER

Good cause exists for the requested continuance ...


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