IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 12, 2011
UNITED STATES OF AMERICA,
The opinion of the court was delivered by: Lawrence J. O'Neill United States District Judge
BENJAMIN B. WAGNER United States Attorney KIMBERLY A. SANCHEZ Assistant U.S. Attorney 2500 Tulare Street, Suite 4401 Fresno, CA 93721 Telephone: (559)497-4000
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR GOVERNMENT TO FILE RESPONSE TO DEFENDANT'S MOTION TO SUPPRESS (NOTE Time Change)
IT IS HEREBY STIPULATED and requested by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and Yan Shrayberman, attorney for defendant, that the December 12, 2011 due date for the Government's response to the defendant's Motion to Suppress be extended to December 27, 2011. The parties further stipulate and request that the Court continue the hearing on the motion and status conference currently scheduled for December 19, 2011 at 1:00 p.m. to January 3, 2012 at 1:00 p.m.
The reason for the requested extension and continuance is extenuating circumstances created by several family emergencies that involved serious medical issues of family members of the undersigned Assistant U.S. Attorney.
The parties further stipulate that the "ends of justice" served by a continuance outweigh the interest of the public and the defendant in a speedy trial, and that the delay occasioned by such continuance is excluded from the Act's time limits pursuant to 18 U.S.C. § 3161(h)(7)(A).
ORDER To enable the Court to return and be prepared, the hearing is rescheduled to January 9, 2012 at 11 a.m. GOOD CAUSE exists. IT IS SO ORDERED.
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