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The United States of America v. Michael Valentino Lovato

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


November 3, 2011

THE UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MICHAEL VALENTINO LOVATO
DEFENDANT.

The opinion of the court was delivered by: Judge: William B. Shubb

KELLY BABINEAU (CA State Bar #190418) 901 H Street, Suite 203 Sacramento, CA 95814 Tel:(916) 442-4948 Fax: (916) 442-8299 kbabineau@klblawoffice.net Attorney for MICHAEL VALENTINO LOVATO

STIPULATION AND [PROPOSED] ORDER

Date: 12/19/11 Time: 9:30 a.m.

This case is currently scheduled for a status hearing on November 7, 2011. The parties have conferred and agree that additional time is need for negotiation between the parties with the hope of resolving the case. Specifically, the parties have agreed that a pre-plea advisory guideline presentence investigation report that addresses Mr. Lovato's criminal history and base offense level, would aid the parties toward resolving the case and respectfully request that this Court order the Probation Office to produce a pre-plea advisory guideline presentence investigation report that addresses the issues of criminal history and base offense level in Mr. Michael Valentino Lovato's case.

It is hereby stipulated and agreed between the United States of America through

JILL THOMAS, Assistant U.S. Attorney, and defendant, MICHAEL VALENTINO LOVATO by and through his attorney, KELLY BABINEAU, Attorney at Law, that the status conference set for November 7, 2011 will continue to December 19, 2011 at 9:30 a.m.

The reasons for this continuance is to give defense counsel additional time to review the discovery with the defendant, to examine possible defenses, to continue investigation of the facts of the case and to continue negotiations with the government. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference. The parties further agree that a pre-plea advisory guideline presentence investigation report that addresses the criminal history and base offense level from the probation office will aid counsel in resolving the case.

IT IS STIPULATED that the period of time from the signing of this Order up to and including the new status conference date of December 19, 2010, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and Local Code T4, for ongoing preparation of counsel Dated: Respectfully submitted,

ORDER

IT IS SO ORDERED. Time is excluded from today's date through and including December 19, 2011 in the interests of justice pursuant to 18 U.S.C. § 3161 (h)(7)(A) [reasonable time to prepare] and Local Code T4.

In addition, the Court further authorizes the United States Probation Office to prepare and disclose to the parties a pre-plea advisory guideline presentence investigation report that addresses the issues of criminal history and base offense level as to Michael Valentino Lovato (Deft #10). The status conference set for November 7, 2011 is continued to December 19, 2011 at 9:30 a.m. as to this defendant.

20111103

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