IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 25, 2011
UNITED STATES OF AMERICA PLAINTIFF,
The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED ORDER].
Time: 9:00 am
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, MICHELE BECKWITH , Assistant Untied States Attorney, attorney for Plaintiff, OLAF HEDBERG, attorney for JUAN HERNANDEZ-LOPEZ., that the status conference now scheduled for February 25, 2011 at 9:00 am be vacated and a new date of April 8, 2011 at 9:00 am be set for a change of plea. Defense counsel has recently recivedThe parties have been negotiating the terms of a proposed plea agreement and will continue to actively do so.
It is further stipulated and agreed between the parties that the period beginning February 25, 2011 and ending April 8, 2011 , should be excluded in computing the time within which the trial of the above criminal prosecution must commence for the purpose of the Speedy Trial Act for defense preparation. 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 cousel/reasonable time for effective preparation, specifically the continuance is requested to allow counsel time to review discovery and conduct investigation) 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, April 8, 2011.
Respectfully submitted, Dated February 24, 2011 By /s/ Olaf Hedberg Olaf W. Hedberg, Attorney at Law Attorney for Juan Hernandez-Lopez Dated this February 24, 2011 Benjamin B. Wagner United States Attorney /s/ Olaf Hedberg for Michele Beckwith Michele Beckwith Assistant U.S. Attorney
IT IS SO ORDERED
February 25, 2011
GARLAND E. BURRELL, JR. United States District Judge
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