IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 27, 2011
UNITED STATES OF AMERICA, PLAINTIFF,
BERTHA RENELL MILTON,
AKA BERTHA RENELL VAUGHN,
The opinion of the court was delivered by: Honorable Anthony W. Ishii
BENJAMIN B. WAGNER United States Attorney JEREMY R. JEHANGIRI Assistant United States Attorneys 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: 559-497-4000 Attorneys for Plaintiff United States of America
STIPULATION AND AGREEMENT TO VACATE JURY TRIAL DATE; ORDER
DATE: To Be Determined
TIME: To Be Determined
The United States of America, by and through Assistant United States Attorney Jeremy R. Jehangiri, and Defendant Bertha Renell Milton, aka Bertha Renell Vaughn, by and through her counsel, David A. Torres, submit this stipulation for the Court's consideration.
IT IS STIPULATED AND AGREED:
1. The parties request that the jury trial date in this case be vacated from the Court's calendar of December 13, 2011, at 9:00 a.m.
2. The parties stipulate that a plea agreement has been reached in this case. The plea agreement was filed with the Court on October 27, 2011.
3. The parties also request that the Court schedule a change of plea hearing at 9:00 a.m. on November 28, 2011, or any other time as the Court deems appropriate.
4. The parties stipulate and agree that the time resulting from consideration by the Court of a proposed plea agreement should be excluded from the calculation of time under the Speedy Trial Act. 18 U.S.C. § 3161(h)(1)(G).
5. Pursuant to the terms of the plea agreement, the parties stipulate and agree that the interests of justice served by accepting this stipulation outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
SO STIPULATED AND AGREED.
IT IS SO ORDERED, with time excluded. IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE
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