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United States v. Gonzalez, 3:17-cr-00436-CRB and (2019)

Court: District Court, N.D. California Number: infdco20191016a50 Visitors: 18
Filed: Oct. 15, 2019
Latest Update: Oct. 15, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER FURTHER CONTINUING CHANGE OF PLEA HEARING CHARLES R. BREYER , Senior District Judge . This matter is currently set for a change of plea hearing on October 16, 2019 at 1:30 p.m. The parties are continuing to attempt to resolve this matter short of trial. However, additional time is needed as the parties are attempting to reach a global resolution that will resolve similar offenses charged in Alameda County. The government is currently working with
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JOINT STIPULATION AND [PROPOSED] ORDER FURTHER CONTINUING CHANGE OF PLEA HEARING

This matter is currently set for a change of plea hearing on October 16, 2019 at 1:30 p.m. The parties are continuing to attempt to resolve this matter short of trial. However, additional time is needed as the parties are attempting to reach a global resolution that will resolve similar offenses charged in Alameda County. The government is currently working with the Alameda County District Attorney's Office to determine whether such an agreement can be reached.

Based on the foregoing, the parties jointly request that the change of plea hearing be continued from October 16, 2019 at 1:30 p.m. to November 20, 2019 at 1:30 p.m. Defense counsel further request, with no objection by the government, that the Court exclude time from October 16, 2019, through November 20, 2019, for effective preparation by defense counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv).

SO STIPULATED:

Respectfully submitted, By: /s/Jeremy Lateiner Jeremy Lateiner Attorneys for Defendant AGUSTIN GONZALEZ By: /s/Aseem Padukone David L. Anderson United States Attorney Aseem Padukone Assistant United States Attorney

[PROPOSED] ORDER

Based on the foregoing stipulation by the parties, and good cause appearing,

IT IS HEREBY ORDERED that:

1. The change of plea hearing shall be continued October 16, 2019 at 1:30 p.m. to November 20, 2019 at 1:30 p.m.

2. The time from October 16, 2019 to November 20, 2019 — a total of 35 days — is excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(iv), for effective preparation of counsel.

ATTORNEY ATTESTATION

I hereby attest, pursuant to Local Rule 5-1(i)(3), that I obtained the concurrence in the filing of this document from the signatories indicated by the conformed signature (/s/).

/s/Jeremy Lateiner Jeremy Lateiner
Source:  Leagle

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