You're viewing Docket Item 16 from the case USA v. Rangel. View the full docket and case details.

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RICHARD A. BESHWATE, JR. 179182
Attorney at Law
2020 Tulare Street Suite A
Fresno, CA 93721
Telephone: (559) 266-5000

Attorney for Defendant, FERNANDO DAVID RANGEL

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

* * * * *

UNITED STATES OF AMERICA, ) CASE NO. 1:13-CR-00280 LJO-SKO
PLAINTIFF, )

V.
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)


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)

)
FERNANDO DAVID RANGEL
)


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STIPULATION AND PROPOSED
ORDER TO CONTINUE STATUS
HEARING

DATE: DECEMBER 16, 2013
TIME: 1:00 PM
JUDGE: HON. SHEILA K. OBERTO



DEFENDANT.











IT IS HEREBY STIPULATED by and between the parties hereto through their respective



















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counsel, RICHARD A. BESHWATE,JR., attorney for Defendant, and Assistant U.S. Attorney,

DAVID GAPPA, Attorney for Plaintiff that the hearing currently scheduled for December 16, 2013, at

1:00 p.m., shall be continued until JANUARY 21, 2014, at 1:00 p.m., or to a date the Court deems

appropriate.





Assistant United States Attorney David Gappa has no objection to this requested continuance.

This continuance is necessary so that defendant's attorney and the AUSA can have sufficient

time to continue ongoing plea negotiations and prepare for Mr. Rangel's hearing.



The parties stipulate that the time until the next hearing should be excluded from the calculation

of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court

excluding such time, so that counsel for the defendant may have reasonable time necessary for effective

preparation, taking into account the exercise of due diligence. 18 U.S.C. §3161(h)(7)(B)(iv).





The parties stipulate and agree that the interests of justice served by this continuance outweigh

the best interest of the public and the defendant in a speedy trial 18 U.S.C.§3161(h)(7)(A).





































Respectfully submitted,
/s/ Richard A. Beshwate, Jr.
RICHARD A. BESHWATE, JR.
Attorney for Defendant, Fernando David Rangel


Dated: December 12, 2013





Dated: December 12, 2013












2014, at 1:00 pm. is GRANTED to allow the parties additional time to achieve a mutually agreeable

Respectfully submitted,
/s/ David Gappa
DAVID GAPPA
Assistant U.S. Attorney

The parties' stipulated request for a continuance of the status conference date to JANUARY 21,













ORDER













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resolution of this matter. Should the parties resolve the case, they shall inform the court so the matter

can be reset as a change of plea hearing before United States District Judge Lawrence J. O'Neill. If the

parties are unable to resolve this matter, they shall be prepared to select a trial date at the January 21,

2014, status conference.

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IT IS SO ORDERED.

Dated: December 12, 2013





/s/ Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE









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TYPE PLEADING NAME

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