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United States of America v. Irena Gerez

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


May 17, 2012

UNITED STATES OF AMERICA PLAINTIFF
v.
IRENA GEREZ, DEFENDANT

The opinion of the court was delivered by: Hon John A Mendez United Sates District Court Judge

STIPULATION TO CONTINUE STATUS (PROPOSED) ORDER DATE: 8/7/2012 Time: 9:30 AM Court: JAM

IT IS HEREBY STIPULATED by and between Assistant United States Attorney Stephen Lapham, Counsel for Plaintiff, and undersigned counsel that the status conference scheduled for May 22, 2012 at 9:30 a.m. be vacated and the matter be continued to this Court's criminal calendar on August 7, 2012,at 9:30 a.m. for further status.

This continuance is requested by the defense in order to permit counsel time to prepare for the defense of this case and to continue negotiations with the prosecution in an effort to reach resolution.

IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161, et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendants further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.

IT IS SO STIPULATED

/S/ STEPHEN LAPHAM Stephen Lapham, Esq., Dated: May 17, 2012 Assistant United States Attorney Attorney for Plaintiff /S/MICHAEL B. BIGELOW Dated: May 17, 2011 Michael B. Bigelow Attorney for Defendant Irena Gerez

ORDER

IT IS ORDERED: that pursuant to stipulation the above referenced

matter shall be continued until August 7, 2012 at 9:30 AM, and

time excluded for the reasons set forth above.

John A. Mendez

20120517

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