Opinion
Case No. 2:06-cr-0014 MCE.
February 23, 2006
JOE GAZZIGLI, Redding, Califronia, Attorney for Defendant RONALD LYERLA.
CAROLYN DELANEY, Assistant US Attorney.
STIPULATION AND REQUEST FOR ORDER TO CONTINUE STATUS CONFERENCE
STIPULATION
IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES HERETO that the STATUS CONFERENCE scheduled for February 28, 2006 at 8:30 am in Department 3 be continued to March 14, 2006 at 8:30 am in Department 11.
This request is made by reason of the fact that Mr. Gazzigli who previously agreed to the original date and time of the STATUS CONFERENCE has, in the interim, been retained by Lee Hazelwood, III who is presently in custody on a three-strikes matter and has a case set for trial without a time waiver pursuant to PC § 1381 for February 28, 2006. Mr. Gazzigli did not represent Mr. Hazelwood at the time this matter was set for Status Conference.
Mr. Gazzigli and Ms. Delaney, Assistant US Attorney, have discussed this conflict and the Government has no objection to the matter being continued to March 14, 2006 at 8:30 am before this honorable court.
The Defendant is further willing to waive time pursuant to the applicable local rules and the seventy (70) day rule of law.
Further, Mr. Gazzigli is authorized to do this on behalf of his client, the Defendant, Ronald Lyerla and the Defendant does agree with this request.
We declare this under penalty of perjury under the laws of the United States of America. Respectfully Submitted: