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United States of America v. Timothy Bernard Baum

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


February 27, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
TIMOTHY BERNARD BAUM,
DEFENDANT.

BENJAMIN B. WAGNER United States Attorney MARK J. McKEON Assistant U.S. Attorney 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: (559) 498-4000 Facsimile: (559) 497-4099 Attorneys for the United States of America

STIPULATION TO CONTINUE JURY TRIAL AND ORDER TO EXCLUDE TIME

The parties request that the following dates may be continued:

EVENT CURRENT DATE NEW DATE

Trial Confirmation and Motions in Limine 8/6/2012 11/5/2012 Jury Trial 9/11/2012 12/11/2011 They stipulate that the time between September 11, 2012 and December 11, 2012 should be excluded from the calculation of time under the Speedy Trial Act because of the unavailability of an essential witness. 18 U.S.C. § 3161(h)(3)(A). Specifically, the government's case agent, Paul Miramontes, will be unavailable on September 11, 2012. He is expecting the birth of his first baby and he will be off of work on paternity leave from August through the beginning of November. As case agent, Special Agent Miramontes conducted interviews of many of the government's witnesses.

The parties further stipulate and agree that the pretrial order may be amended to change the following dates:

Motions in limine 6/18/2012 9/17/2012 Response 7/16/2012 10/15/2012 Reply 7/30/2012 10/29/2012 Trial documents 9/6/2012 12/6/2012

ORDER

IT IS SO ORDERED.

CHIEF UNITED STATES DISTRICT JUDGE

20120227

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