Opinion
Case No. 1:12-CR-00264-AWI
04-30-2013
UNITED STATES OF AMERICA, Plaintiff, v. SHAUNA MARIE FABREGA Defendant.
DALE A. BLICKENSTAFF - #40681 Attorney at Law Attorney for Defendant, SHAUNA MARIE FABREGA BENJAMIN B. WAGNER United States Attorney GRANT B. RABENN Assistant U.S. Attorney
DALE A. BLICKENSTAFF - #40681
Attorney at Law
Attorney for Defendant,
SHAUNA MARIE FABREGA
STIPULATION AND ORDER FOR
CONTINUANCE OF STATUS
CONFERENCE
Date : May 13, 2013
Judge : Barbara McAuliffe
It is hereby stipulated by and between Benjamin B. Wagner, United States Attorney and Grant B. Rabenn, Assistant U.S. Attorney and Dale A. Blickenstaff, Attorney for SHAUNA MARIE FABREGA, that the Status Conference set for May 13, 2013 at 1:00 p.m. be taken off calendar and instead the matter set for further status conference on June 24, 2013 at 1:00 p.m
The defense has received a plea agreement and its contents have been discussed with Ms. Fabrega. Ms. Fabrega is a single mother raising four children with the youngest being born on November 27, 2012. Ms. Fabrega needs additional time to make arrangements for the placement of her children before her anticipated incarceration. Also, since she lives in Palmdale, California, it is difficult for her to travel to Fresno for discussions with defense counsel regarding the evidence in the case. She has met with defense counsel one time and another conference is necessary to complete a thorough review of the evidence. The additional time is necessary to complete the foregoing tasks.
The parties agree that the time between the date of this stipulation and the new status conference hearing date of June 24, 2013 at 1:00 p.m., shall be excluded in the interests of justice, including but not limited to continuity of counsel and reasonable time necessary for effective preparation pursuant to 18 U.S.C. Sections 3161(h)(7)(A) and 3161(h)(7)(B)(I) and (iv).
For the reasons set forth above, the parties respectfully request that the hearing scheduled for May 13, 2013 at 1:00 p.m. be dropped from the calendar and a new status conference be scheduled for June 24, 2013 at 1:00 p.m.
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By ____________________
GRANT B. RABENN
Assistant U.S. Attorney
By ____________________
DALE BLICKENSTAFF
Attorney for SHAUNA MARIE FABREGA
IT IS SO ORDERED.
Time is excluded pursuant to 18 U.S.C. Sections 3161(h)(7)(A) and 3161(h)(7)(B)(I) and (iv).
IT IS SO ORDERED.
Barbara A. McAuliffe
UNITED STATES MAGISTRATE JUDGE