Opinion
BENJAMIN B. WAGNER, United States Attorney, JASON HITT, Assistant U.S. Attorney, Sacramento, California.
MARK REICHEL, Esq., Attorney for Gerardo ARREDONDO.
STIPULATION AND [PROPOSED] ORDER RESETTING THE EVIDENTIARY HEARING DATE ON DEFENDANT'S MOTION TO DISMISS THE INDICTMENT
WILLIAM B. SHUBB, District Judge.
The parties, plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant Gerardo ARREDONDO, by and through his counsel, Mark Reichel, Esq., stipulate and agree that the evidentiary hearing date of June 18, 2013, at 9:30 a.m., should be reset for July 30, 2013, at 9:30 a.m.
The joint request is based upon defense counsel's need for additional time to prepare for the hearing by reviewing statements of anticipated government witnesses and view exhibits anticipated to be introduced at the evidentiary hearing, as well as meet with government counsel to attempt to resolve the matter before the evidentiary hearing date. Both parties believe that a resolution of the case prior to the evidentiary hearing could result in a significant benefit the defendant because it would likely result in less prison time than if the defendant is not successful on his motion to dismiss. For these reasons, the parties respectfully request that the Court reset the evidentiary hearing date of June 18, 2013, to July 30, 2013, at 9:30 a.m.
ORDER
Based upon the representations and stipulation of counsel, IT IS HEREBY ORDERED that:
1. The evidentiary hearing set for June 18, 2013, is hereby vacated; and
2. An evidentiary hearing on the pending motion to dismiss the indictment is set for July 30, 2013, at 9:30 a.m.
IT IS SO ORDERED.