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United States of America v. Irena Gerez

November 9, 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 ORDER DATE: 1/15/2013 Time: 9:45 AM Court: JAM

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 matter was set for status on November 13, 2012.

2. By this stipulation, defendant now moves to continue the status conference until January 15, 2013 at 9:45 a.m. and to exclude time between, November 13, 2012 2012 and January 15, 2013 under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery

associated with this case includes: investigative reports and

related documents in electronic form 1,800 pages of documents.

All of his discovery has been either produced directly to

counsel and/or made available for inspection and copying.

b. Counsel for defendant desires additional time to consult with his/her client, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with his client, to prepare pretrial motions, and to otherwise prepare for trial.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation, taking ...


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