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HEATHER E. WILLIAMS, #122664
Federal Defender
MATTHEW C. BOCKMON, #161566
Assistant Federal Defender
801 I Street, 3rd Floor
Sacramento, CA 95814
Telephone: 916.498.5700/Fax: 916-498-5710
matthew.bockmon@fd.org

Attorney for Defendant
DEQUAN PATTERSON



IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF CALIFORNIA



UNITED STATES OF AMERICA,

Plaintiff,

vs.

DEQUAN PATTERSON,

Defendant.


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Case No. 2:12-CR-0437 TLN
2:12-CR-0436 TLN

STIPULATION AND ORDER VACATING
JURY TRIAL AND MOTION HEARING
DATES AND SETTING STATUS
CONFERENCE

Date: September 12, 2013
Time: 9:30 a.m.
Judge: Hon. Troy L. Nunley









At the defendant’s request, the United States of America through Assistant United States

Attorney Todd Leras together with the defendant Dequan Patterson through Assistant Federal

Defender Matthew C. Bockmon agree to vacate the jury trial and motion hearing dates of August

1, 2013 and August 5, 2013 and set the matter for status hearing on September 12, 2013 for the

following reasons:



Mr. Patterson requests additional investigation regarding a potential witness; counsel for

the defendant needs additional time to review and research issues regarding a roll over warrant

for pinging cell phone tower searches; Mr. Patterson yesterday received the government’s

written plea offer to resolve both cases, and needs additional time to review the offer with his

attorney.



The parties agree that period of delay from August 1, 2013 until September 12, 2013

shall be excluded in computing the time within which the trial must commence based upon delay

Stipulation and Order to Continue

-1-

U.S. v Patterson, 2:12-CR-0437 TLN

2:12-CR-0436 TLN





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resulting from the pending Fed.R.Evid. 404(b) motion under 18 U.S.C. § 3161(h)(1)(D) and

delay resulting from a continuance at the request of the defendant and his counsel for the reasons

stated above under 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare] and Local

Code T4 based upon continuity of counsel and defense preparation.

Dated: July 30, 2013























HEATHER E. WILLIAMS
Federal Defender

/s/ MATTHEW C. BOCKMON
MATTHEW C. BOCKMON
Assistant Federal Defender
Attorney for Defendant
DEQUAN PATTERSON



































Dated: July 30, 2013 _/s/ DEQUAN PATTERSON__





Dated: July 30, 2013







BENJAMIN WAGNER
United States Attorney



























/s/ MATTHEW C. BOCKMON for
Todd Leras
Assistant U.S. Attorney
Attorney for Plaintiff











DEQUAN PATTERSON
(Original Signature Retained by Attorney)







UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the

ORDER

August 1, 2013 motion hearing and the jury trial date of August 5, 2013 are hereby vacated and a

status conference is scheduled for September 12, 2013 at 9:30 a.m. Based on the representation

of defense counsel and good cause appearing therefrom, the Court hereby finds that the failure to

grant a continuance in this case would deny defense counsel reasonable time necessary for

effective preparation, taking into account the exercise of due diligence. The Court finds that the

ends of justice to be served by granting a continuance outweigh the best interests of the public

and the defendant in a speedy trial. It is ordered that time up to and including the September 12,

Stipulation and Order to Continue

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U.S. v Patterson, 2:12-CR-0437 TLN

2:12-CR-0436 TLN





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2013 status conference shall be excluded from computation of time within which the trial of this

matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(7)(A)

and (B)(iv) and Local Code T4, to allow defense counsel reasonable time to prepare.



Dated: July 31, 2013

Stipulation and Order to Continue

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U.S. v Patterson, 2:12-CR-0437 TLN

2:12-CR-0436 TLN