Opinion
Case No.: 10-CR-00495 LJO
09-15-2011
UNITED STATES OF AMERICA, Plaintiff, v. FELIPA VARGAS Defendant
DAVID A. TORRES Attorney for Defendant Felipa Vargas HENRY ZAZUETA CARBAJAL, III U. S. Attorney
LAW OFFICE OF DAVID A. TORRES
Attorney at Law, SBN 135059
Attorney for Defendant
FELIPA VARGAS
STIPULATION AND ORDER TO
ADVANCE SENTENCING HEARING
TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE: LAWRENCE J. O'NEILL AND HENRY ZAZUETA CARBAJAL, III, UNITED STATES ATTORNEY:
COMES NOW Defendant, FELIPA VARGAS by and through her attorney of record, DAVID A. TORRES hereby requesting that the sentencing hearing currently set for September 23, 2011, be advance to September 19, 2011 at 8:30 a.m., or a date convenient to court and counsel.
This is a mutual agreement between myself, and United States Attorney Henry Zacueta Carbajal, III . I was advised by the court clerk that the matter could be advanced prior to Friday, September 23, 2011 and requesting that the matter be heard on September 19, 2011.
The defendant is willing to continue, excluding time through the next court appearance and that the ends of justice in the exclusion outweigh defendant's speedy trial rights.
Based upon the foregoing, I respectfully request that this matter be advanced to September 19, 2011
The parties also agree that the delay resulting from the continuance shall be excluded in the interest of justice pursuant to 18 U.S.C. §3161 (h)(7)(A) and §3161 (h)(7)(B)(i) & (iv).
IT IS SO STIPULATED.
DAVID A. TORRES
Attorney for Defendant
Felipa Vargas
HENRY ZAZUETA CARBAJAL, III
U. S. Attorney
ORDER
IT IS SO ORDERED. Time is excluded in the interest of justice pursuant to 18 U.S.C. §3161(h)(7)(A) and §3161 (h)(7)(B)(i) & (iv).
LAWRENCE J. O'NEILL
United States District Judge