Opinion
1:11-cr-00045-AWI
10-27-2011
UNITED STATES OF AMERICA, Plaintiff, v. BERTHA RENELL MILTON, aka BERTHA RENELL VAUGHN, Defendant.
Jeremy R. Jehangiri Assistant United States Attorney David A. Torres Attorney for Defendant Bertha Renell Milton aka Bertha Renell Vaughn
BENJAMIN B. WAGNER
United States Attorney
JEREMY R. JEHANGIRI
Assistant United States Attorneys
Attorneys for Plaintiff
United States of America
STIPULATION AND AGREEMENT TO VACATE JURY TRIAL DATE; ORDER
DATE: To Be Determined
TIME: To Be Determined
Honorable Anthony W. Ishii
The United States of America, by and through Assistant United States Attorney Jeremy R. Jehangiri, and Defendant Bertha Renell Milton, aka Bertha Renell Vaughn, by and through her counsel, David A. Torres, submit this stipulation for the Court's consideration.
IT IS STIPULATED AND AGREED:
1. The parties request that the jury trial date in this case be vacated from the Court's calendar of December 13, 2011, at 9:00 a.m.
2. The parties stipulate that a plea agreement has been reached in this case. The plea agreement was filed with the Court on October 27, 2011.
3. The parties also request that the Court schedule a change of plea hearing at 9:00 a.m. on November 28, 2011, or any other time as the Court deems appropriate.
4. The parties stipulate and agree that the time resulting from consideration by the Court of a proposed plea agreement should be excluded from the calculation of time under the Speedy Trial Act. 18 U.S.C. § 3161(h)(1)(G).
5. Pursuant to the terms of the plea agreement, the parties stipulate and agree that the interests of justice served by accepting this stipulation outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
SO STIPULATED AND AGREED.
Jeremy R. Jehangiri
Assistant United States Attorney
David A. Torres
Attorney for Defendant
Bertha Renell Milton
aka Bertha Renell Vaughn
ORDER
IT IS SO ORDERED, with time excluded. IT IS SO ORDERED.
___________________________
CHIEF UNITED STATES DISTRICT JUDGE