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United States of America v. Tasha Hoa Kelly and Teona Williams

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


April 4, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
TASHA HOA KELLY AND TEONA WILLIAMS,
DEFENDANT.

Robert M. Holley (SBN 50769) Attorney at Law 331 J Street, Ste. 200 Sacramento, CA 95814 Telephone: (916)443-2213 Counsel for TEAONA WILLIAMS

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE REASONS FOR REQUEST

The parties hereto have been actively in the process of negotiating a settlement in this matter for the purpose of avoiding unnecessary expenditure of trial time for both the parties and the Court. Ms. Williams and her counsel have met with the Assistant United States Attorney along with the case agent and the results of that meeting are still being considered. It is requested that the matter be continued for status conference for an additional three weeks. This request for continuance is made by stipulation and proposed order to save the Court and the lawyers the unnecessary expenditure of court time.

STIPULATION

It is hereby stipulated by and between the parties hereto through their respective counsel that the status conference in the above-entitle case, presently set for Monday, April 4,2011 at 8:30 a.m. be continued without appearance, for the reasons set forth above, to Monday, April 25, 2011 at 8:30 a.m.

The parties further stipulate that time included in this continuance be excluded pursuant to the Speedy Trial Act, 18 U.S.C Section 3161 (h)(8)(B)(ii)(Local Codes T2 and T4) through April 25, 2011, in the interest of justice to allow the parties further time for preparation of this case and negotiation towards settlement.

ORDER

GOOD CAUSE APPEARING, and upon stipulation of the parties, it is hereby ordered that the status conference in the above entitled case, presently scheduled for Monday, April 4, 2011 at 8:30 a.m. be continued to Monday, April 25, 2011 at 8:30 a.m.

It is further ordered that the time be excluded through April 25, 2011 pursuant to the Speedy Trial Act exclusion sections set forth in the stipulation above.

20110404

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