ROBERT L. FORKNER (CSB# 166097) Law Offices of Robert L. Forkner 722 Thirteenth Street Modesto, CA 95354 Telephone: (209)544-0200 Fax: (209)544-1860 Attorney for Defendant JOSE MIGUEL LIZARRAGA
STIPULATION AND (PROPOSED) ORDER CONTINUING JURY TRIAL
Defendant JOSE MIGUEL LIZARRAGA, through his attorney ROBERT L. FORKNER, together with the United States of America through its undersigned counsel, Yasin Mohammad, Assistant United States Attorney, hereby stipulate and request the following:
1. The Jury Trial presently set for May 17, 2010 be continued to July 12, 2011, at 8:30 a.m., thus vacating the presently set Jury Trial conference.
2. The parties further request that the presently scheduled Trial Readiness Conference set for May 2, 2011 also be continued to a later date such as June 20, 2011 at 9:00 a.m.
3. Defense counsel Robert L. Forkner has requested the continuance due to a conflict in his calendar. Counsel will began a Jury Trial that was previously scheduled for May 17, 2011 at 8:30 am in Stanislaus County.
4. This continuance is also requested because defense counsel needs additional time to prepare, including reviewing discovery, obtaining needed records, identifying and interviewing potential witnesses, conducting legal research, and identifying potential motions to be filed.
5. Further, 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) and agree to exclude time from the date of the filing of the order until the date of the Jury Trial.
ROBERT L. FORKNER (CSB# 106697) Law Offices of Robert L. Forkner 722 Thirteenth Street Modesto, CA 95354 Telephone: (209)544-0200 Fax: (209)544-1860 Attorney for Defendant JOSE MIGUEL LIZARRAGA
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. JOSE MIGUEL LIZARRAGA, Defendants.
ORDER TO CONTINUE JURY TRIAL
GOOD CAUSE APPEARING, it is hereby ordered that the May 17, 2011 Jury Trial be continued to July 12, 2011 at 8:30 a.m. and that the Trial Readiness Conference presently set for May 2, 2011 be continued to June 20, 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 ...