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United States of America v. Alejandro Manuel Perez

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


March 27, 2013

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
ALEJANDRO MANUEL PEREZ,
AKA "DRO"
DEFENDANT.

The opinion of the court was delivered by: Hon. Sheila K. Oberto

STIPULATION TO CONTINUE APRIL 15, 2013 HEARING ON DISCOVERY MOTION TO MAY 20, 2013; ORDER

Date: May 20, 2013 Time: 1:00 p.m. Ctrm: 7

IT IS HEREBY STIPULATED by and between the parties hereto, through their respective attorneys of record, that the parties' April 15, 2013 hearing on defendant's discovery motion and underlying briefing deadlines be continued as follows:

1. United States' Response Brief, from March 29, 2013 until May 3, 2013;

2. Defendant's Reply Brief, if any, from April 5, 2013 until May 10, 2013; and

3. Discovery Hearing, from April 15, 2013 until May 20, 2013.

The parties base this stipulation on good cause. To explain, counsel for the government met earlier this week with the lead agent on the case to go over the issues addressed in defendant's discovery motion, as well as an attendant letter sent directly to government counsel. Pursuant to that meeting, the prosecution team developed a game plan with respect to how it could try to gather additional information in the case.

Yesterday, however, the lead agent's wife was admitted to the hospital with respect to an unexpectedly early delivery of twins. Accordingly, counsel for the government understands the agent will need to be out of the office for the next several weeks.

Significantly, the parties do not ask that the October 1, 2013 trial date be continued.

For the above-stated reason, the stipulated continuance will conserve time and resources for both parties and the court, and the delay resulting from this continuance shall be excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(ii).

BENJAMIN B. WAGNER United States Attorney Dated: March 22, 2013 By: _Brian W. Enos Brian W. Enos Assistant U.S. Attorney (As auth. 3/22/13) Dated: March 22, 2013 /s/ Kyle J. Humphrey Kyle J. Humphrey Attorney for Defendant

ORDER

IT IS SO ORDERED.

Sheila K. Oberto UNITED STATES MAGISTRATE JUDGE

20130327

© 1992-2013 VersusLaw Inc.



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