UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
January 8, 2013
UNITED STATES OF AMERICA,
YVONNE LEAH CHAVEZ, ET AL.
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 600 University Avenue Palo Alto, California 94301 650/326-2980 -- Telephone 650/326-9704 -- Facsimile email@example.com Counsel for Defendant Yvonne Chavez
STIPULATION AND [PROPOSED] ORDER CONTINUING SENTENCING HEARING XXXXXXXX
Defendant Yvonne Leah Chavez, by and through her attorney Michael W. Armstrong, 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 January 14, 21
2013, at 1:30 p.m., to February 25, 2013, at 1:30 p.m. before the Honorable Edward J. Davila.
Defense counsel, Michael Armstrong, is anticipating starting a felony
jury trial in the Redwood City Superior Court on January 14, 2013,
and the trial is expected to 24 last a couple of weeks. For this
reason, Mr. Armstrong will be unavailable on January 14, 2013, 25 and
after consultation with counsel for the government and Probation
Officer Benjamin Flores,
U.S. v. Yvonne Chavez, et al. Case Nos. CR 11-00549 CR 11-00561 EJD
Stipulation and Proposed Order Continuing Sentencing Hearing
it has been agreed that the next convenient date for all parties
involved is February 25, 2013. 2
The parties agree that the time from January 14, 2013 through February 25, 2013 is properly excluded pursuant to the Speedy Trial Act, Title 18 United States Code, sections 3161(h)(7)(A) and 3161(h)(7)(B)(iv) in the interests of justice.
IT IS SO STIPULATED.
Michael W. Armstrong Attorney for Defendant YVONNE CHAVEZ Date: January 8, 2013 /S/ 10 Thomas M. O'Connell Assistant United States Attorney U.S. v. Yvonne Chavez, et al. Case Nos. CR 11-00549 CR 11-00561 EJD Stipulation and Proposed Order Continuing Sentencing Hearing
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the sentencing hearing currently set for January 14, 2013, is continued to February 25, 2013, 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 January 14, 2013 through February 25, 2013. 8
IT IS SO ORDERED.
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