Opinion
CASE NO. 1:09-cr-00075-AWI
10-13-2011
UNITED STATES OF AMERICA, Plaintiff, v. JOSE TALAVERA, Defendant.
Preciliano Martinez Attorney for Defendant JOSE TALAVERA Kathleen Servatius Assistant U.S. Attorne Attorney for Plaintiff UNITED STATES OF AMERICA
PRECILIANO MARTINEZ
ATTORNEY AT LAW
State Bar No. 93253
Attorney for Defendant
JOSE TALAVERA
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE/
MOTION HEARING DATE
IT IS HEREBY STIPULATED by and between Assistant United States Kathleen Servatius, Counsel for Plaintiff, Attorney Preciliano Martinez, Counsel for Defendant Jose Talavera, that the Status Conference/ Motion Hearing date scheduled for October 17, 2011, at 9:00 a.m. be vacated and the Status Conference/ Motion Hearing be continued to this court's calendar on November 7, 2011 at 9:00 a.m. Mr. Martinez has a preliminary hearing for a murder trial in Stanislaus County.
The court is advised that counsel have conferred about this request that they have agreed to the court date of November 7, 2011 and that Ms. Servatius has authorized Preciliano Martinez to sign this stipulation on her 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 November 7, 2011.
Respectfully Submitted,
Preciliano Martinez
Attorney for Defendant
JOSE TALAVERA
Kathleen Servatius
Assistant U.S. Attorne
Attorney for Plaintiff
UNITED STATES OF AMERICA
ORDER
Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current October 17, 2011 Status Conference/ Motion Hearing is hereby vacated and reset to November 7, 2011.
IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE ____