United States
v.
Duran

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISIONJan 18, 2012
No. CR 11-0594 (N.D. Cal. Jan. 18, 2012)

No. CR 11-0594

01-18-2012

UNITED STATES OF AMERICA, Plaintiff, v. Dagoberto Duran, Defendant

Peter A. Leeming, SBN 119124 Attorney for: Defendant Dagoberto Duran Thomas O'Connell, Assistant U.S. Attorney


Peter A. Leeming, SBN 119124


Attorney for: Defendant Dagoberto Duran


STIPULATION AND [] ORDER CONTINUING STATUS CONFERENCE HEARING

The parties stipulate, and request that the court Order, the following:

1. This matter is currently set for a status hearing on January 19, 2012 at 9:00 A.M.

2. The parties are negotiating a settlement of this matter. The defense is investigating, and hopes to present to the government, mitigating materials that will help resolve this case. This process is not yet complete, and counsel for Mr. Duran expects the defense investigation to take at least another two weeks.

3. For the above reasons, and for the effective preparation of counsel and the need for the defense to complete its investigation of this matter, the parties respectfully request that the status hearing date of January 19, 2012 be vacated, and a new hearing be set for February 16, 2012, at 9:00 A.M.

4. The parties request that the time from January 19, 2012 to February 16, 2012 be excluded from the Speedy Trial Act, 18 USC Sect. 3161 (h)(7)(A) and (B)(iv).

Respectfully submitted,

_______________


PETER A. LEEMING,


Attorney for Dagoberto Duran


Thomas O'Connell,


Assistant U.S. Attorney
IT IS SO ORDERED.

_______________


Hon. D. Lowell Jensen


United States District Judge