IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
August 22, 2012
UNITED STATES OF AMERICA,
JOSE DIEGO CONTRERAS-RAMIREZ,
The opinion of the court was delivered by: Lawrence J. O'Neill United States District Judge
STIPULATION REGARDING JURY INSTRUCTION AND SPECIAL VERDICT FILING; FINDINGS AND ORDER STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate as follows:
1. By previous order, this Court ordered the filing of jury instructions and special verdict forms by the parties by Wednesday, August 22, 2012, for a trial date of September 11.
2. By this stipulation, the parties now move to continue the filing date for jury instructions and special verdict forms to August 24.
3. The parties agree and stipulate, and request that the Court find the following:
a. The parties have reached a tentative plea agreement. Defense counsel has been unable to meet in person with his client, who is housed at Lerdo, until today, the filing date for jury instructions and special verdict forms.
b. Based on the above-stated findings, the parties believe they have stated good cause to extend the filing date of jury instructions and special verdict forms.
IT IS SO STIPULATED.
DATED: August 22, 2012. Respectfully submitted, BENJAMIN B. WAGNER United States Attorney ALYSON BERG Assistant United States Attorney /s/ Karen A. Escobar KAREN A. ESCOBAR Assistant United States Attorney DATED: August 22, 2012. /s/ Victor Chavez VICTOR CHAVEZ Counsel for Defendant
IT IS SO ORDERED.
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