IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
April 11, 2013
UNITED STATES OF AMERICA,
The opinion of the court was delivered by: Judge: Hon. Lawrence J. O'Neill
STIPULATION TO VACATE STATUS
CONFERENCE AND SET FOR CHANGE OF
PLEA IN DISTRICT COURT AND ORDER ) THEREON
Date: April 29, 2013
Time: 8:30 a.m.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, BRIAN W. ENOS, Assistant United States Attorney, counsel for plaintiff, and ERIC V. KERSTEN, Assistant Federal Defender, counsel for defendant Timothy Valdez, that the date for status conference in this matter may, currently scheduled for April 15, 2013, before the Honorable Sheila K. Oberto, may be continued to April 29, 2013, before the Honorable Lawrence J. O'Neill . The date currently set for status conference is April 15, 2013 The requested new date is April 29, 2013, before the Honorable Lawrence J. O'Neill.
The government has extended a plea offer that will likely resolve this matter. It is therefore requested that pending status conference be rescheduled in the district court. It is further requested that a short continuance be granted to allow time for defense counsel to review the government's offer with Mr. Valdez, who is housed in the Lerdo/Kern County Detention facility.
The parties agree that the delay resulting from the continuance shall be excluded as necessary for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). For this reason, the ends of justice served by the granting of the requested continuance outweigh the interests of the public and the defendant in a speedy trial.
BENJAMIN B. WAGNER United States Attorney DATED: April 11, 2013 By /s/ Brian W. Enos BRIAN W. ENOS Assistant United States Attorney Attorney for Plaintiff JOSEPH SCHLESINGER Acting Federal Defender DATED: April 11, 2013 By /s/ Eric V. Kersten ERIC V. KERSTEN Assistant Federal Defender Attorney for Defendant Timothy Valdez
IT IS SO ORDERED. The intervening period of delay is excluded in the interests of justice.
IT IS SO ORDERED.
Lawrence J. O'Neill UNITED STATES DISTRICT JUDGE
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