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United States of America v. Jose Talavera and Heriberto Avalos

June 16, 2011

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOSE TALAVERA AND HERIBERTO AVALOS,
DEFENDANTS



PRECILIANO MARTINEZ ATTORNEY AT LAW State Bar No. 93253 801 15th St, Suite F Modesto, CA 95354 (209)579-2206/ (209)579-2211 FaX Attorney for Defendant JOSE TALAVERA

STIPULATION RE: CONTINUANCE AND ORDER

IT IS HEREBY STIPULATED by and between Assistant United States Kathleen Servatius, Counsel for Plaintiff, Attorney Preciliano Martinez, Counsel for Defendant Jose Talavera and Attorney Carlos Fuentes, Counsel for Defendant Heriberto Avalos, that the Status Conference date scheduled for June 20, 2011, at 9:00 a.m. be vacated and the Status Conference be continued to this court's calendar on June 27, 2011 at 9:00 a.m. Additional time is needed for attorneys to review plea agreements with clients.

The court is advised that counsel have conferred about this request that they have agreed to the court date of June 27, 2011 and that Ms. Servatius and Mr. Fuentes have authorized Preciliano Martinez to sign this stipulation on their behalf.

The parties agree and stipulate that time should be excluded under the Speedy Trial Act pursuant to Local Code T4 for completion of plea negotiations, up to and including June 27, 2011.

UNITED STATES OF AMERICA

ORDER

Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current June 20, 2011 Status Conference hearing is hereby vacated and reset to June 27, 2011.

IT IS SO ORDERED.

CHIEF UNITED STATES DISTRICT JUDGE

20110616

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