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MELINDA HAAG (CABN 132612)
United States Attorney

J. DOUGLAS WILSON (DCBN 412811)
Chief, Criminal Division

ROBERT S. LEACH (CABN 196191)
KYLE F. WALDINGER (ILBN 6238304)
Assistant United States Attorneys

450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-7200
Fax: (415) 436-7234
Email: [email protected][email protected]

Attorneys for United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

ADOREAN BOLEANCU,

Defendant.

CASE NO. CR 13-0444 RS

STIPULATION AND [PROPOSED] ORDER
SETTING BRIEFING SCHEDULE FOR MOTIONS
IN LIMINE AND FILING DATE FOR JOINT
PRETRIAL STATEMENT

Trial Date:
September 23, 2013
Pretrial Date: September 18, 2013

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The above-captioned case is set for trial on September 23, 2013. A pretrial conference is

scheduled for September 18, 2013 at 2:00 p.m. The parties hereby submit this stipulation to set a

briefing schedule with respect to the parties’ motions in limine and a filing date for the parties’ joint

pretrial statement.

1.

Pursuant to the Court’s Guidelines for Final Pretrial Conference in Jury Cases, the parties

are to file pretrial motions in limine at least 10 days before the final pretrial conference. The Guidelines

provide that the parties are to file oppositions at least three days before the pretrial conference.

2.

Because the parties anticipate that they will each be filing pretrial motions in limine, and

STIPULATION AND [PROPOSED] ORDER
CR 13-0444 RS

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in order to provide the parties with additional time to respond, the parties have jointly agreed to set the

following briefing schedule for those motions in limine:

a.

b.

Motions in limine to be filed:

September 6, 2013

Responses to motion in limine to be filed:

September 13, 2013

3.

The parties believe that the briefing schedule set forth above will aid the Court in

determining whether any evidentiary matters may be resolved before trial. It will also provide each

party with additional time to respond to the opposing party’s motions.

4.

The Court’s Guidelines for Final Pretrial Conference in Jury Cases also provide that the

parties should lodge and serve a joint pretrial statement at least 10 days before the pretrial conference.

Because that day falls on a weekend, and in order to provide the parties with additional time to complete

the joint pretrial statement, the parties jointly request that the Court allow them to file the joint pretrial

statement on September 9, 2013.

SO STIPULATED.

DATED: August 30, 2013

SO STIPULATED.

DATED: August 30, 2013

MELINDA HAAG
United States Attorney

________/s/______________________
KYLE F. WALDINGER
Assistant United States Attorney

________/s/_______________________
ETHAN A. BALOGH
Attorney for the defendant Adorean Boleancu

[PROPOSED] ORDER

For the reasons set forth in the parties’ stipulation, the Court adopts the briefing schedule

for motions in limine and the filing date for the joint pretrial statement proposed by the parties.

IT IS SO ORDERED.

DATED:

8/30/13

STIPULATION AND [PROPOSED] ORDER
CR 13-0444 RS

_______________________________
HON. RICHARD SEEBORG
United States District Judge