Opinion
CASE NO. 1:09-cr-00075-AWI
08-31-2011
UNITED STATES OF AMERICA, Plaintiff, v. JOSE TALAVERA Defendant.
Preciliano Martinez Attorney for Defendant JOSE TALAVERA Kathleen Servatius Assistant U.S. Attorney Attorney for Plaintiff UNITED STATES OF AMERICA
PRECILIANO MARTINEZ
ATTORNEY AT LAW
Attorney for Defendant
JOSE TALAVERA
STIPULATION RE: CONTINUANCE AND ORDER
Dept.: 2
Honorable Judge Anthony W. Ishii
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 and Motion Hearing date scheduled for September 6, 2011, at 9:00 a.m. be vacated and the Status Conference and Motion Hearing be continued to this court's calendar on October 17, 2011 at 9:00 a.m. Additional time is needed for Mr. Martinez to review the plea agreement with the defendant Jose Talavera. The government shall file any responses to defendant's motion to suppress by September 19, 2011.
The court is advised that counsel have conferred about this request that they have agreed to the court date of October 17, 2011 and that Ms. Servatius has 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 17, 2011.
Respectfully Submitted,
Preciliano Martinez
Attorney for Defendant
JOSE TALAVERA
Kathleen Servatius
Assistant U.S. Attorney
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 September 6, 2011 Status Conference hearing is hereby vacated and reset to October 17, 2011.
IT IS SO ORDERED.
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CHIEF UNITED STATES DISTRICT JUDGE