UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
July 28, 2011
UNITED STATES OF AMERICA,
JOSEPH MICHAEL SMITH,
The opinion of the court was delivered by: Hon. Anthony W. Ishii
GINA TENNEN, ESQ. LibertyBell Law Group, P.C. 235 E. Olive Ave., 4th Floor Burbank, California 91502 Telephone: (818) 563-2355 Facsimile: (818) 748-1515 Attorney for Joseph Michael Smith
STIPULATION TO CONTINUE HEARING ON CHANGE OF PLEA; ORDER Date: August 1, 2011 Time: 11:00 A.M.
IT IS HEREBY STIPULATED by and between the parties hereto, through their respective attorneys of record, that the change of plea hearing presently set for Monday, August 1, 2011 at 11:00 a.m., be continued to Monday, August 29, 2011, at 11:00 a.m.
The parties base this stipulation on good cause, in that the parties are still currently in the negotiations of finalizing the plea agreement under rule 11 (C)(1)(C) . The parties expect that the stipulated continuance would allow them to finalize the plea agreement and be prepared to participate in a change of plea hearing on August 29, 2011.
For the above-stated reason, the stipulated continuance will allow for completion of negotiations and conserve time and resources for both parties and the Court. The delay resulting from this continue shall be excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A)and 3161 (h)(7) (B) (ii).
IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE
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