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United States of America v. Nicolas Zoquitecatl

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


January 30, 2013

UNITED STATES OF AMERICA, PLAINTIFF,
v.
NICOLAS ZOQUITECATL,
DEFENDANT

The opinion of the court was delivered by: Lawrence J. O'Neill United States District Judge

STIPULATION TO CONTINUE CHANGE OF PLEA HEARING; ORDER DATE: February 19, 2013 TIME: 8:30 a.m. JUDGE: Hon. Lawrence J. O'Neill

The parties, through their respective counsel, Assistant United States Attorney, Laurel Montoya, and Assistant Federal Defender, Victor M. Chavez, hereby stipulate that the present court date of February 4, 2013 may be moved to February 19, 2013. The parties jointly seek this stipulation to permit the parties to finalize some details of their plea agreement. The government needs to confer with its case agent. Mr. Zoquitecatl is housed at Lerdo and the parties wish to avoid bringing him to court under these circumstances.

The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice herein and for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv) because the ends of justice served in granting such continuance outweigh the best interests of the public and the defendant in a speedy trial.

BENJAMIN B. WAGNER United States Attorney DATED: January 30, 2013 By: /s/ Laurel J. Montoya LAUREL J. MONTOYA Assistant United States Attorney Attorney for Plaintiff JOSEPH SCHLESINGER Acting Federal Public Defender DATED: January 30, 2013 By: /s/ Victor M. Chavez VICTOR M. CHAVEZ Assistant Federal Defender Attorneys for Defendant NICOLAS ZOQUITECATL

ORDER

IT IS SO ORDERED.

20130130

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