Filed: Dec. 13, 2016
Latest Update: Dec. 13, 2016
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA HEARING AS TO DEFENDANT GONZALES — CORRECTED KANDIS A. WESTMORE , Magistrate Judge . Defendant CHARLES GONZALES, by and through his counsel undersigned, and the United States of America, through MICHAEL A. RABKIN, Trial Attorney, United States Department of Justice, Antitrust Division, hereby stipulate and respectfully request that the Court vacate the Change of Plea hearing in the above captioned case, currently set for Thurs
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA HEARING AS TO DEFENDANT GONZALES — CORRECTED KANDIS A. WESTMORE , Magistrate Judge . Defendant CHARLES GONZALES, by and through his counsel undersigned, and the United States of America, through MICHAEL A. RABKIN, Trial Attorney, United States Department of Justice, Antitrust Division, hereby stipulate and respectfully request that the Court vacate the Change of Plea hearing in the above captioned case, currently set for Thursd..
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STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA HEARING AS TO DEFENDANT GONZALES — CORRECTED
KANDIS A. WESTMORE, Magistrate Judge.
Defendant CHARLES GONZALES, by and through his counsel undersigned, and the United States of America, through MICHAEL A. RABKIN, Trial Attorney, United States Department of Justice, Antitrust Division, hereby stipulate and respectfully request that the Court vacate the Change of Plea hearing in the above captioned case, currently set for Thursday, December 15, 2016, at 09:30 a.m., and reset it for Thursday, January 26, 2017, at 09:30 a.m.
This is the parties' first request to continue the Change of Plea hearing as to Defendant Gonzales. The parties last appeared before the Court on September 21, 2016 for status.
Discovery from the government is complete, and on Tuesday, November 22, 2016, a revised plea offer was extended to the defendant.
The requested continuance is necessary to allow defense counsel reasonable time to thoroughly review the revised plea offer extended by the government and to discuss this plea offer with the defendant.
For these above-stated reasons, the defendant, defense counsel, and the government stipulate and respectfully request that the Court vacate the Change of Plea hearing currently set for Thursday, December 15, 2016 and reset it for Thursday, January 26, 2017, at 9:30 a.m.
IT IS SO STIPULATED.
DATED: December 8, 2016 /s/ MAR
MICHAEL A. RABKIN,
Trial Attorney
United States Dept. of Justice
Antitrust Division
IT IS SO ORDERED.
