BENJAMIN B. WAGNER United States Attorney JASON HITT WILLIAM S. WONG Assistant U.S. Attorneys 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2751
STIPULATION AND [PROPOSED] ORDER SETTING STATUS CONFERENCE FOR DEFENDANTS
Plaintiff, United States of America, by its counsel, Assistant United States Attorneys Jason Hitt and William S. Wong, and defendants Benjamin SANTOS CASTRO, by and through his counsel Scott Cameron, Esq., Oscar CAMPOS PADILLA, by and through his counsel Paul Meltzer, Esq., Alvaro GOMEZ, by and through his counsel Thomas Johnson, Esq., and Valdemar CAMBUNGA, by and through his counsel Candace Fry, Esq., stipulate and agree that the existing status conference date of June 13, 2011, should be vacated. The parties further stipulate and agree that a status conference should be set for May 9, 2011, at 8:30 a.m. for defendants Benjamin SANTOS CASTRO, Oscar CAMPOS PADILLA, Alvaro GOMEZ, and Valdemar CAMBUNGA.
The status conference is needed because the June 13, 2011 status conference date for these defendants was premised upon waiting for the conclusion of the trial set of the Group II defendants in April. However, each of the Group II defendants have entered guilty pleas and there is no longer any reason to await the conclusion of that trial. Accordingly, the parties respectfully request that the Court set a status conference date for the remaining four defendants in this case on May 9, 2011, because it should achieve a more efficient setting of trial dates or resolution of the case for these remaining defendants.
Based upon the representations and stipulation of counsel, IT IS HEREBY ORDERED that:
1. A status conference in this matter for defendants Benjamin SANTOS CASTRO, Oscar CAMPOS PADILLA, Alvaro GOMEZ, and Valdemar CAMBUNGA is set for May 9, 2011, at 8:30 a.m.; and
2. The previously-set status conference date for these defendants of June 13, 2011, is VACATED.
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