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United States of America v. Daniel Vasquez-Miranda and Zoila Vazquez-Vazquez

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


October 27, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
DANIEL VASQUEZ-MIRANDA AND ZOILA VAZQUEZ-VAZQUEZ,
DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. Lawrence J. O'Neill

STIPULATION TO CONTINUE STATUS CONFERENCE; [PROPOSED] ORDER

Date: November 14, 2011 Time: 1:00 p.m.

IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective attorneys of record herein, that the status conference now set for October 28, 2011, may be continued to November 14, 2011, at 1:00 p.m.

The reason for the continuance is to allow for further case preparation, investigation, and plea negotiations. Specifically, the parties reached a tentative oral agreement this afternoon, which needs to be reduced to writing. The continuance is necessary to allow the government to prepare and send a new written offer to defendants and for time for defense counsel to review the revised offers with defendants. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial and that the delay from the continuance shall be excluded from the calculation of time under the Speedy Trial Act pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).

Dated: October 27, 2011 Respectfully submitted, BENJAMIN B. WAGNER United States Attorney By: /s/ Ian L. Garriques IAN L. GARRIQUES Assistant U.S. Attorney Dated: October 27, 2011 By: /s/ Jeremy S. Kroger JEREMY S. KROGER Attorney for Defendant DANIEL VASQUEZ-MIRANDA Dated: October 27, 2011 By: /s/ Katherine L. Hart KATHERINE L. HART Attorney for Defendant ZOILA VAZQUEZ-VAZQUEZ

ORDER

The intervening period of delay shall be excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(iv).

IT IS SO ORDERED.

Lawrence J. O'Neill UNITED STATES DISTRICT JUDGE

20111027

© 1992-2011 VersusLaw Inc.



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