Opinion
NO.: CR 12-0057 EMC
03-20-2013
UNITED STATES OF AMERICA, Plaintiff, v. CAEZARINE DONELSON, Defendant.
KEVIN BARRY Assistant United States Attorney JAMES PHILLIP VAUGHNS. Attorney for Defendant DONELSON
JAMES PHILLIP VAUGHNS, State Bar #124040
Law Offices of James Phillip Vaughns
6114 LaSalle Avenue, Ste 289
Oakland, California 94611
Telephone: 510-583-9622
Facsimile: 510-886-7218
Attorney for Caezarine DONELSON
STIPULATION AND PROPOSED
ORDER CONTINUING CHANGE OF
PLEA HEARING DATE
STIPULATION
The parties stipulate as follows: 1. Mr. Donelson recently received new, revised, proposed disposition terms from AUSA Kevin Barry. 2. Mr. Donelson has not yet received the Pre-Plea Presentence report due to the requirement that a consent form be signed and returned to the U.S. Probation Officer. Counsel mailed the form to Mr. Donelson, but has not received it back to date. Moreover, counsel has not yet been able to discuss the new, revised, plea terms with him. 3. AUSA Barry has no objection to this matter being continued to April 3, 2013, at 2:30 p.m. 4. The parties further stipulate and agree that the time between March 20, 2013 and April 3, 2013 should be excluded under the Speedy Trial Act, specifically pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) to allow effective preparation of counsel. IT IS SO STIPULATED
_________________
KEVIN BARRY
Assistant United States Attorney
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JAMES PHILLIP VAUGHNS.
Attorney for Defendant DONELSON
UNITED STATES OF AMERICA, Plaintiff,
v. CAEZARINE DONELSON, Defendant.
NO.: CR 12-0057 EMC
ORDER
The Court hereby ORDERS that the Change of Plea Hearing scheduled for March 20, 2013 be vacated and rescheduled for April 3, 2013, at 2:30 p.m. Time shall be excluded from March 20, 2013 through April 3, 2013 to facilitate the effective preparation of counsel.
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Judge Edward M. Chen