Opinion
CASE NO. 2:09-cr-00380-WBS
09-16-2011
UNITED STATES OF AMERICA, Plaintiff, v. URIEL OCHOA ESPINDOLA, JOSE SERGIO ESPINDOLA, ARMANDO ESPINDOLA, AND VALENTIN RAMIREZ-CARDINEZ. Defendants.
Preciliano Martinez Attorney for Defendant URIEL OCHOA ESPINDOLA Michael Beckwith Assistant United States Attorney Attorney for Plaintiff Jeffrey Rosenblum Matthew Bockmon Attorney for Defendant JOSE SERGIO ESPINDOLA John Duree Attorney for Defendant ARMANDO ESPINDOLA Robert Forkner Attorney for Defendant VALENTIN RAMIREZ CARDINEZ
PRECILIANO MARTINEZ
ATTORNEY AT LAW
Attorney for Defendant
URIEL OCHOA ESPINDOLA
STIPULATION [PROPOSED ORDER] TO
CONTINUE STATUS CONFERENCE
Dept.: 5
Honorable William B. Shubb
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Michael Beckwith, Counsel for Plaintiff, Attorney Preciliano Martinez, Counsel for Defendant Uriel Ochoa Espindola, Attorney Jeffrey Rosenblum, Counsel for Defendant Jose Sergio Espindola, Attorney John Duree, Counsel for Armando Espindola, and Attorney Robert Forkner, Counsel for Defendant Valentin Ramirez Cardinez, that the Status Conference date scheduled for September 19, 2011, at 8:30 a.m. be vacated and the Status Conference be continued to this court's calendar on October 24, 2011 at 8:30 a.m. Additional time is needed for attorneys to negotiate plea agreements.
The court is advised that counsel have conferred about this request that they have agreed to the court date of October 24, 2011 and that Mr. Beckwith, Mr. Rosenblum, Mr. Duree, and Mr. Forkner have authorized Preciliano Martinez to sign this stipulation on their behalf.
The parties agree and stipulate that time should be excluded under the Speedy Trial Act pursuant to Local Code T4 for completion of plea negotiations, up to and including October 24, 2011.
Respectfully Submitted,
Preciliano Martinez
Attorney for Defendant
URIEL OCHOA ESPINDOLA
Michael Beckwith
Assistant United States Attorney
Attorney for Plaintiff
Jeffrey Rosenblum
Matthew Bockmon
Attorney for Defendant
JOSE SERGIO ESPINDOLA
John Duree
Attorney for Defendant
ARMANDO ESPINDOLA
Robert Forkner
Attorney for Defendant
VALENTIN RAMIREZ
CARDINEZ
ORDER
Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current September 19, 2011 Status Conference hearing is hereby vacated and reset to October 24, 2011.
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE