IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 3, 2013
UNITED STATES OF AMERICA,
BENJAMIN B. WAGNER United States Attorney KIMBERLY A. SANCHEZ Assistant U.S. Attorney 2500 Tulare Street, Suite 4401 Fresno, CA 93721 Telephone: (559)497-4000
STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE RESPONSE SET A DATE FOR A REPLY AND CONTINUANCE OF STATUS CONFERENCE AND MOTIONS
IT IS HEREBY STIPULATED by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and David Balakian, attorney for Salvador Valencia-Galvan, that the time for the government to file its response to the defendant's motion to suppress currently due January 4, 2013 be extended to January 11, 2013; that the date for the defendant's reply to the government's response be vacated; and that the hearing on the motion and status conference remain on January 14, 2013 at 1:30 p.m. Counsel have engaged in further plea negotiations and believe that the case has a potential of settlement without necessitating proceeding with the suppression motion. The parties will be able to determine whether resolotion of the matter is going to occur prior to the government's response date of January 11, 2013. Should the parties reach an agreement, the parties will file another stipulation setting a date for a change of plea. The parties further agree that time will be excluded through the Court's ruling on the motions. Moreover, the parties further request the Court to enter an Order finding that the "ends of justice" served by a continuance outweigh the interest of the public and the defendant in a speedy trial, and that the delay occasioned by such continuance is excluded from the Act's time limits pursuant to 18 U.S.C. § 3161(h)(7)(A).
IT IS SO ORDERED.
UNITED STATES DISTRICT JUDGE
© 1992-2013 VersusLaw Inc.