IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
April 27, 2011
UNITED STATES OF AMERICA
The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
Olaf W. Hedberg, SBN #151082 Olaf W. Hedberg, Attorney at Law 901 H St., Suite 673 Sacramento, CA 95814 (916) 447-1192 Attorney for Defendant
STIPULATION AND [PROPOSED
Date: April 29, 2011
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 April 29, 2011 at 9:00 am be vacated and a new date of June 10, 2011 at 9:00 am be set for a change of plea. The 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 April 29, 2011 and ending June 10, 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 counsel/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, June 10, 2011.
IT IS SO ORDERED
GARLAND E. BURRELL, JR. United States District Judge
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