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United States of America v. Yvonne Leah Chavez

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


September 20, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
YVONNE LEAH CHAVEZ, ET AL.
DEFENDANTS.

The opinion of the court was delivered by: Hon. Edward J. Davila United States District Judge

Michael W. Armstrong (SBN 87799) NOLAN, ARMSTRONG & BARTON LLP 2 600 University Avenue Palo Alto, California 94301 3 650/326-2980 -- Telephone 650/326-9704 -- Facsimile 4 marmstrong@nablaw.com 5 Counsel for Defendant Yvonne Chavez 6 7

STIPULATION AND [PROPOSED] ORDER CONTINUING SENTENCING HEARING XXXXXXXX

STIPULATION

Defendant Yvonne Leah Chavez, by and through her attorney Michael W. Armstrong, 19 and the United States, by and through Assistant United States Attorney Thomas O'Connell, 20 hereby agree and stipulate to continue the sentencing hearing now scheduled for October 1, 21 2012, at 1:30 p.m., to November 5, 2012, at 1:30 p.m. before the Honorable Edward J. Davila. 22

The parties so stipulate and request this extension because the probation officer, Benjamin Flores, needs more time in which to prepare his presentence report in this matter. 24

Once provided with Mr. Flores' report, both parties will need adequate time in which to review 25 the report and make their objections and changes if necessary.

U.S. v. Yvonne Chavez, et al. Case Nos. CR 11-00549 CR 11-00561 EJD Stipulation and Proposed Order Continuing Sentencing Hearing The parties agree that the time between October 1, 2012 through November 5, 2012 is 2 properly excluded pursuant to the Speedy Trial Act, Title 18 United States Code, sections 3

IT IS SO STIPULATED.

3161(h)(7)(A) and 3161(h)(7)(B)(iv) in the interests of justice.

ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the sentencing 3 hearing currently set for October 1, 2012, is continued to November 5, 2012, at 1:30 p.m. For 4 the reasons stated above, the Court further finds that the ends of justice served by granting the 5 requested continuance outweigh the best interests of the public and the defendant in a speedy 6 trial, pursuant to 18 U.S.C. § 3161(h)(7)(A) and 3161(h)(8)(7)(iv). Accordingly, time shall be 7 excluded from October 1, 2012 November 5, 2012. 8

IT IS SO ORDERED. 9

20120920

© 1992-2012 VersusLaw Inc.



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