The opinion of the court was delivered by: Honorable Oliver W. Wanger
CHANGE OF PLEA HEARING;ORDER
DATE: TO BE DETERMINED
TIME: TO BE DETERMINED
STIPULATION AND AGREEMENT TO
VACATE JURY TRIAL DATE AND SET
The United States of America, by and through Assistant United States Attorney Jeremy R. Jehangiri, and Defendant Angel Landin, by and through his counsel Anthony P. Capozzi, submit this stipulation for the Court's consideration.
IT IS STIPULATED AND AGREED: 1. Defendant Angel Landin, by and through counsel of record, requests that the jury trial date, currently set for August 16, 2011, be vacated and removed from the Court's calendar.
2. The parties have engaged in extensive plea negotiations and have come to an agreement for Defendant to plead guilty.
3. The parties, by and through undersigned counsel, request that a change of plea hearing be set for August 1, 2011.
4. The plea agreement, by and between the parties, will be filed with the Court prior to Defendant Angel Landin's change of plea hearing.
5. The parties, by and through undesigned counsel, further request that all motions deadlines be vacated.
6. Undersigned counsel for the United States and Defendant herein will also be engaged in another jury trial before this Court on August 16, 2011, involving a different defendant.
7. There should be no delay in this case. However, any delay resulting from this stipulation and agreement shall be excluded in the interests of justice, and the ends of justice in endorsing this stipulation through formal order outweigh the interests of Defendant Angel Landin's and the public in a speedy trial. See 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(ii).
SO STIPULATED AND AGREED.
Dated: July 20, 2011 Jeremy R. Jehangiri Assistant United States Attorney Dated: July 21, 2011 (as authorized) Anthony P. Capozzi Attorney for Defendant, Akop Krboyan
The change of plea shall be taken on August 1,2011, in Courtroom 3 at 9:00 a. m. The trial date shall be ...