The opinion of the court was delivered by: Honorable William B. Shubb
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 URIEL OCHOA ESPINDOLA
STIPULATION [PROPOSED ORDER] TO CONTINUE STATUS CONFERENCE Date: October 24, 2011 Time: 8:30a.m. Dept.: 5
IT IS HEREBY STIPULATED by and between Assistant United States Attorney
Michael Beckwith, Counsel for Plaintiff, Attorney Preciliano Martinez, Counsel for Defendant Uriel Ochoa Espindola, Attorney Jeffrey Rosenblum, Counsel for Defendant Jose Sergio Espindola, Attorney John Duree, Counsel for Armando Espindola, and Attorney Robert Forkner, Counsel for Defendant Valentin Ramirez Cardinez, that the Status Conference date scheduled for September 19, 2011, at 8:30 a.m. be vacated and the Status Conference be continued to this court's calendar on October 24, 2011 at 8:30 a.m. Additional time is needed for attorneys to negotiate plea agreements.
The court is advised that counsel have conferred about this request that they have agreed to the court date of October 24, 2011 and that Mr. Beckwith, Mr. Rosenblum, Mr. Duree, and Mr. Forkner 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 October 24, 2011.
Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current September 19, 2011 Status Conference hearing is hereby vacated and reset to October 24, 2011.
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