United Statesv.Tulud

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISIONFeb 13, 2013
No. CR -12-00408 - DLJ (PSG) (N.D. Cal. Feb. 13, 2013)

No. CR -12-00408 - DLJ (PSG)

02-13-2013

UNITED STATES OF AMERICA, Plaintiff, v. MELQUIADEZ TULUD, Defendant.

GEOFFREY A. HANSEN, Acting Federal Public Defender MANUEL U. ARAUJO Assistant Federal Public Defender Counsel for Defendant TULUD


GEOFFREY A. HANSEN,
Acting Federal Public Defender
MANUEL U. ARAUJO
Assistant Federal Public Defender
Counsel for Defendant TULUD

STIPULATION TO CONTINUE

STATUS HEARING TO MARCH 7,

2013; [] ORDER


HONORABLE D. LOWELL JENSEN


STIPULATION

Defendant and the government, through their respective counsel, subject to the court's approval, hereby stipulate that the Court continue the status hearing in the above-captioned matter, presently scheduled for February 14, 2013, at 9:00 a.m., to March 7, 2013, at 9:00 a.m. The reason for the stipulation is as follows. The government has provided discovery and the defense has reviewed it. The discovery includes a number of spread sheets regarding the loss amount. The parties have engaged in discussions regarding a settlement of the matter, and have reached a tentative agreement which needs to proceed along the United States Attorney's approval process. Defense counsel will need to review and discuss the anticipated plea agreement and its terms once the government makes its final plea offer. It is anticipated that an additional three weeks will be necessary to complete the process and/or complete any additional investigation. Mr. Tulud lives in Kern County, and he must travel by public transportation.

The parties further agree and stipulate that time should be excluded from and including February 14, 2013, through and including March 7, 2013, to provide counsel reasonable time to prepare, pursuant to Speedy Trial Act, 18 U.S.C. §3161(h)(7)(A) and (B)(iv). Accordingly, the United States and the defendant agree that granting the requested exclusion of time will serve the interest of justice and outweigh the interest of the public and defendant in a speedy trial.

____________________


MANUEL ARAUJO,


Assistant Federal Public Defender


_________________________


MEREDITH J. EDWARDS,


Assistant United States Attorney


[] ORDER

Good cause appearing and by stipulation of the parties, it is hereby ordered that the status conference hearing in the above-captioned matter is continued from February 14, 2013, at 9:00 a.m., to March 7, 2013, at 9:00 a.m. It is further ordered that the period of delay from February 14, 2013, through and including February 11, 2013, be excluded for purposes of Speedy Trial Act computations pursuant to Title 18, United States Code, Sections 3161(h)(7)(A) and 3161(h)(7)(B)(iv).

___________________________________


HONORABLE D. LOWELL JENSEN,


United States District Judge