Stipulation to Continue Status Conference; Proposed Order — No. 1:21-cr-00144 (Dkt. 31, E.D. Cal.)

Summary

A three-page Stipulation to Continue Status Conference with proposed order, Document 31, filed 09/15/22 in United States v. Cecilia Navil Aquino, No. 1:21-cr-00144, in the U.S. District Court for the Eastern District of California, signed September 13, 2022 by Robert Lamanuzzi for the defendant and Assistant United States Attorney Joseph Barton for United States Attorney Phillip A. Talbert. The parties ask that the status conference set for September 21, 2022 at 1:00 p.m. be continued to October 19, 2022 at 1:00 p.m. before Magistrate Judge Sheila K. Oberto: the government has produced discovery, and defense counsel has more investigation to do and has asked for a proposed plea agreement. Time under the Speedy Trial Act is excluded through October 19, 2022 under 18 U.S.C. §§ 3161(h)(7)(A) and (B)(i) and (iv). Judge Oberto so ordered on 9/14/2022.

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“Stipulation to Continue Status Conference; Proposed Order — No. 1:21-cr-00144 (Dkt. 31, E.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-continue-status-conference-proposed-order-no-1-21-cr-00-08c3900458/, SHA-256 d7206fa4362c2d12d832acc64e2d2ddae01757e895f8b9af3b549fc531fdecf9.

Full text

     Case 1:21-cr-00144-JLT-SKO Document 31 Filed 09/15/22 Page 1 of 3


1    PHILLIP A. TALBERT
     United States Attorney
2    JOSEPH D. BARTON
     Assistant United States Attorney
3    2500 Tulare Street, Suite 4401
     Fresno, CA 93721
4    Telephone: (559) 497-4000
     Facsimile: (559) 497-4099
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6    Attorneys for Plaintiff
     United States of America
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9                             IN THE UNITED STATES DISTRICT COURT
10                          FOR THE EASTERN DISTRICT OF CALIFORNIA
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12    UNITED STATES OF AMERICA                           Case No. 1:21-cr-00144-NONE-SKO
13                   Plaintiff,                          STIPULATION TO CONTINUE STATUS
                                                         CONFERENCE; PROPOSED ORDER
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            v.
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      CECILIA NAVIL AQUINO,                              DATE: September 21, 2022
16                                                       TIME:  1:00 p.m.
                     Defendant.                          JUDGE: Hon. Sheila K. Oberto
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            IT IS HEREBY STIPULATED by and between the parties through their respective
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     counsel that the Status Conference scheduled for September 21, 2022, at 1:00 p.m., may be
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     continued until October 19, 2022, at 1:00 p.m., before the Honorable Sheila K. Oberto. The
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     government has produced discovery to defense counsel. Defense counsel has further
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     investigation to perform and has requested a proposed plea agreement from the government. The
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     parties agree that time under the Speedy Trial Act shall be excluded through October 19, 2022, in
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     the interests of justice, including but not limited to, the need for effective defense preparation
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     and defense investigation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
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     ///
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     ///
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     Case 1:21-cr-00144-JLT-SKO Document 31 Filed 09/15/22 Page 2 of 3


1    The parties also agree that the ends of justice served by taking this action outweigh the best
2    interests of the public and of the defendant to a speedy trial.
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4     Dated: September 13, 2022                            /s/ Robert Lamanuzzi
                                                           ROBERT LAMANUZZI
5                                                          Counsel for Defendant Cecilia Aquino
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      Dated: September 13, 2022                            /s/ Joseph Barton
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                                                           JOSEPH BARTON
8                                                          Assistant United States Attorney

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     Case 1:21-cr-00144-JLT-SKO Document 31 Filed 09/15/22 Page 3 of 3


1    PHILLIP A. TALBERT
     United States Attorney
2    JOSEPH D. BARTON
     Assistant United States Attorney
3    2500 Tulare Street, Suite 4401
     Fresno, CA 93721
4    Telephone: (559) 497-4000
     Facsimile: (559) 497-4099
5
6    Attorneys for Plaintiff
     United States of America
7
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                              IN THE UNITED STATES DISTRICT COURT
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                           FOR THE EASTERN DISTRICT OF CALIFORNIA
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      UNITED STATES OF AMERICA                           Case No. 1:21-cr-00144-NONE-SKO
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                     Plaintiff,                          ORDER
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            v.
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      CECILIA NAVIL AQUINO,
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                     Defendant.
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                                                 ORDER
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            Upon the Parties’ stipulation and for good cause shown, the Status Conference scheduled
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     for September 21, 2022, at 1:00 p.m., is continued until October 19, 2022, at 1:00 p.m., before
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     the Honorable Sheila K. Oberto. The period through October 19, 2022, inclusive, is excluded
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     pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
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            IT IS SO ORDERED.
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25    DATED: 9/14/2022
                                                   HONORABLE SHEILA K. OBERTO
26                                                 UNITED STATES MAGISTRATE JUDGE

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