Opinion
No. 2:11-cr-00295-MCE
02-13-2013
UNITED STATES OF AMERICA, Plaintiff, v. SERGEY POTEPALOV, et al., Defendants.
MICHAEL E. HANSEN Attorney for Defendant SERGEY POTEPALOV Michael E. Hansen for CHRISTOPHER HAYDN-MYER Attorney for Defendant PAVEL BEREZENKO Michael E. Hansen for ROBERT HOLLEY Attorney for Defendant ANTHONY RIVERA Michael E. Hansen for MICHAEL LONG Attorney for Defendant VERANIKA KOUSHAL BENJAMIN B. WAGNER United States Attorney By: Michael E. Hansen for DANIEL McCONKIE, JR. Assistant U.S. Attorney Attorney for Plaintiff
Michael E. Hansen
Attorney at Law, SBN 191737
Attorney for Defendant
SERGEY POTEPALOV
AMENDED STIPULATION AND ORDER TO VACATE TRIAL DATE, AND TO SET STATUS CONFERENCES/CHANGE OF PLEA HEARINGS
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Daniel McConkie, Jr., Assistant United States Attorney, attorney for plaintiff; Michael E. Hansen, attorney for defendant Sergey Potepalov; Christopher Haydn-Myer, attorney for defendant Pavel Berezenko; Robert Holley, attorney for defendant Anthony Rivera; and Michael Long, attorney for defendant Veranika Koushal, that the previously-scheduled jury trial date of March 18, 2013, be vacated. All parties are negotiating plea agreements.
It is expected that defendant Anthony Rivera will enter a change of plea on February 7, 2013. Defendant Veranika Koushal will enter a change of plea on February 21, 2013. Defendants Pavel Berezenko and Sergey Potepalov will enter changes of plea on March 7, 2013.
Accordingly, we request status conferences/change of plea hearings as described above.
The Government concurs with this request.
Further, the parties agree and stipulate that time will be excluded up to and including March 7, 2013.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED.
Respectfully submitted,
________
MICHAEL E. HANSEN
Attorney for Defendant
SERGEY POTEPALOV
Michael E. Hansen for
CHRISTOPHER HAYDN-MYER
Attorney for Defendant
PAVEL BEREZENKO
Michael E. Hansen for
ROBERT HOLLEY
Attorney for Defendant
ANTHONY RIVERA
Michael E. Hansen for
MICHAEL LONG
Attorney for Defendant
VERANIKA KOUSHAL
BENJAMIN B. WAGNER
United States Attorney
By: Michael E. Hansen for
DANIEL McCONKIE, JR.
Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order.
The Court orders that time up to and including March 7, 2013, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. sections 3161(h)(7)(B)(ii) and (iv), and Local Codes T2 [complex case] and T4 [reasonable time for defense counsel to prepare].
IT IS SO ORDERED.
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MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE