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United States v. Farmer

United States District Court, Ninth Circuit

January 27, 2014

UNITED STATES OF AMERICA, Plaintiff,
v.
JULIE DIANNE FARMER, Defendant.

BENJAMIN B. WAGNER, United States Attorney, KIRK E. SHERRIFF, HENRY Z. CARBAJAL III, CHRISTOPHER D. BAKER, Assistant United States Attorneys, Fresno, CA, Attorneys for Plaintiff United States of America.

ANTHONY P. CAPOZZI, Law Offices of Anthony P. Capozzi, Attorney for defendant Julie Dianne Farmer.

STIPULATION & ORDER CONTINUING TRIAL DATE AND RESETTING PRETRIAL DATES

LAWRENCE J. O'NEILL, District Judge.

Plaintiff the United States of America ("government") and defendant JULIE DIANNE FARMER, by and through their respective counsel of record, jointly stipulate as follows:

1. Defendant Farmer asserts that, despite defense counsel's diligence and best efforts to complete investigation steps for trial, the defense needs additional time (i) to further investigate matters addressed in interview reports produced by the government, (ii) to designate expert witnesses on handwriting, if necessary based on such further investigation, (iii) to hold the further hearing regarding the remaining proposed testimony of Dr. Terrell, (iv) to provide additional time for the government to designate an expert witness responsive to Dr. Terrell, if necessary, and (v) to designate rebuttal experts, if necessary, regarding the government's four expert witnesses.
2. The government and defendant Farmer stipulate and jointly request that the Court order that the trial date be continued to April 8, 2014, and that the following additional deadlines be set in this case:
a. Feb. 10, 2014, at 11:00am: Hearing regarding the remaining proposed testimony of Dr. Terrell.
b. Feb. 18, 2014: Designation of any rebuttal expert witnesses due.
c. March 10, 2014: Motions in limine (if any) due regarding newly designated expert witnesses.
d. March 17, 2014: Oppositions due re motions in limine.
e. March 24, 2014: Joint proposed jury instructions, proposed disputed jury instructions, objections to disputed jury instructions, and proposed verdict form(s) and objections thereto (if any) to be filed and served.
f. March 31, 2014, at 11:00am: Hearing on proposed disputed jury instructions and proposed verdict form, and on motions in limine (if any). (The parties have previously exchanged proposed jury instructions and verdict forms in this case and have met and conferred on these matters. The parties currently believe that there may be certain limited disputed issues to be addressed with the Court. The parties will continue to confer regarding the jury instructions and verdict form and will promptly notify the Court if this hearing can be vacated).
g. April 1, 2014: Witness lists, proposed voir dire, and trial briefs to ...

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