govinfo:USCOURTS-caed-2_11-cr-00427-40

Stipulation and Order - 1 
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ERIN J. RADEKIN 
Attorney at Law - SBN 214964 
428 J Street, Suite 350 
Sacramento, California 95814 
Telephone: (916) 446-3331 
Facsimile: (916) 447-2988 
 
Attorney for Defendant 
ANGELA SHAVLOVSKY 
 
 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, ) 2:11-CR-00427 LKK 
 ) 
 Plaintiff, ) STIPULATION AND ORDER 
 ) TO CONTINUE STATUS CONFERENCE 
v. ) 
 ) 
 ) 
ANGELA SHAVLOVSKY, ) 
 ) 
 Defendant. ) 
__________________________________ ) 
 
 
STIPULATION 
 
 Plaintiff, United States of America, by and through its counsel, 
Assistant United States Attorney Jill Thomas, and defendant, Angela 
Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate 
to vacate the date set for status conference, August 12, 2014 at 9:15 a.m., 
in the above-captioned matter, and to continue the status conference to 
September 16, 2014 at 9:15 a.m. in the courtroom of the Honorable Lawrence K. 
Karlton. 
 The reason for this request is that additional time is needed by Ms. 
Radekin to complete review of discovery, which is voluminous (discovery 
currently ends with item/page number 63026, counsel has reviewed through 7078 
as of this date) and includes a number of recordings. There is also 

 
Stipulation and Order - 2 
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additional defense preparation and investigation Ms. Radekin needs to 
complete. The Court is advised that Ms. Thomas concurs with this request and 
has authorized Ms. Radekin to sign this stipulation on her behalf. 
 The parties further agree and stipulate that the time period from the 
filing of this stipulation until September 16, 2014 should be excluded in 
computing time for commencement of trial under the Speedy Trial Act, based 
upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local 
Code T4, to allow reasonable time necessary for effective defense 
preparation. It is further agreed and stipulated that the ends of justice 
served in granting the request outweigh the best interests of the public and 
the defendant in a speedy trial. 
 Accordingly, the parties respectfully request the Court adopt this 
proposed stipulation. 
IT IS SO STIPULATED 
Dated: August 7, 2014 BENJAMIN WAGNER 
 United States Attorney 
 
 By: /s/ Jill Thomas 
 JILL THOMAS 
 Assistant United States Attorney 
 
Dated: August 7, 2014 /s/ Erin J. Radekin 
 ERIN J. RADEKIN 
 Attorney for Defendant 
 ANGELA SHAVLOVKSY 
 
 
 
ORDER 
 For the reasons set forth in the accompanying stipulation and 
declaration of counsel, the status conference date of August 12, 2014 at 9:15 
a.m. is VACATED and the above-captioned matter is set for status conference 
on September 16, 2014 at 9:15 a.m. The Court finds excludable time in this 
matter through September 16, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and 

 
Stipulation and Order - 3 
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Local Code T4, to allow reasonable time necessary for effective defense 
preparation. For the reasons stipulated by the parties, the Court finds that 
the interest of justice served by granting the request outweigh the best 
interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 
3161(h)(7)(A), (h)(7)(B)(iv). 
IT IS SO ORDERED. 
Dated: August 8, 2014 

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