Public.Resource.org v. United States Internal Revenue Service

Filing 65

***PLEASE DISREGARD - INCORRECT DOCUMENT IMAGE ATTACHED***STIPULATION AND ORDER EXTENDING PLAINTIFF'S TIME TO MOVE TO RECOVER ATTORNEYS' FEES AND COSTS by Hon. William H. Orrick granting 64 Stipulation. Plaintiff's deadline to file a motion to recover attorneys fees and costs shall be extended until March 16, 2015. (jmdS, COURT STAFF) (Filed on 2/10/2015) Modified on 2/10/2015 (jmdS, COURT STAFF).

1 MELINDA HAAG (CABN 132612)
United States Attorney
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DAVID R. CALLAWAY (CABN 121782)
3 Chief, Criminal Division
4 KATIE BURROUGHS MEDEARIS (CABN 262539)
Assistant United States Attorney
1301 Clay Street, Suite 340S
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Oakland, California 94612
Telephone: [phone]
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FAX: [phone]
[e-mail]
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8 Attorneys for United States of America
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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UNITED STATES OF AMERICA,
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Plaintiff,
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v.
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ORACIO TAPIA,
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Defendant.

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Case No.15-CR-0053-WHO
STIPULATION AND ORDER RESCHEDULING
THE CHANGE OF PLEA FROM FEBRUARY 12,
2015 TO MARCH 19, 2015 AND EXCLUDING
TIME UNDER SPEEDY TRIAL ACT

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STIPULATION

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Defendant Oracio Tapia (hereafter, the “Defendant”) was charged on January 22, 2015 by

23 Information with Conspiracy to Distribute and Possess With the Intent to Distribute Methamphetamine.
24 The parties have reached a pretrial resolution, but require additional time before the next appearance to
25 finalize the language and terms of the proposed plea agreement, as well as to allow time for defense
26 counsel to confer with his in-custody client regarding the draft agreement. As such, the parties ask the
27 Court to continue this matter to March 19, 2015 or a date as soon thereafter as the Court’s schedule
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STIP. AND ORDER
15-CR-0053-WHO

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The parties further request that time be excluded under the Speedy Trial Act, 18 U.S.C. § 3161,

2 between January 22, 2105 and March 19, 2015 to allow for the effective preparation of counsel and
3 continuity of counsel, as defense counsel is unavailable for the multiple weeks in February, 2015.
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IT IS SO STIPULATED.

5 DATED: February 9, 2015
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______________/s/_________________
KATIE BURROUGHS MEDEARIS
Assistant United States Attorney

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______________/s/_________________
STEVEN KALAR
Counsel for Oracio Tapia

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STIP. AND ORDER
15-CR-0053-WHO

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ORDER

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For the reasons stated by the parties, the Court finds that the aforementioned request is supported

3 by good cause. Court therefore grants the parties’ request to reschedule the change of plea from
4 February 12, 2015 to March 19, 2015 and excludes time between such dates under the Speedy Trial Act.
5 18 U.S.C. § 3161.
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IT IS SO ORDERED.

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8 Dated: February 9, 2015
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HONORABLE WILLIAM H. ORRICK
United States District Judge

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STIP. AND ORDER
15-CR-0053-WHO

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