The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
Timothy E. Warriner Attorney at Law 813 6th St., Suite 450 Sacramento, CA 95814 (916) 443-7141 Attorney for defendant, JEFFREY EUGENE CONNER
STIPULATION AND [PROPOSED] ORDER
Date: July 8, 2011 Time: 9:00 a.m.
The parties hereby stipulate to the following:
1. A status conference in this matter is now set for June 3, 2011 at 9:00 a.m.
2. Both parties jointly request that the status conference be continued to permit additional time to engage in plea negotiations, including a joint meeting concerning possible plea. Additionally, defense counsel is waiting to obtain discovery items, and to review that material. Time for preparation of counsel continues to be needed to obtain and review discovery materials, to prepare possible pretrial motions, to engage in plea negotiations, to investigate issues concerning the client's criminal history as that may pertain to any proposed plea agreement, and to meet with the client and government's counsel. Both parties, therefore, stipulate that the status conference be continued until July 8, 2011.
3. It is further stipulated by the parties that time continue to be excluded to July 8, 2011 for preparation of counsel pursuant to local code T4. 18 U.S.C. 3161(h)(7)(B)(iv).
GOOD CAUSE APPEARING, it is hereby ordered that the status conference set for June 3, 2011 be continued to July 8, 2011 at 9:00 a.m., and that time continue to be excluded to July 8, 2011, for preparation of counsel pursuant to Local Code T4, 18 U.S.C. 3161(h)(7)(B)(iv).
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