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RALPH HURVITZ

ATTORNEY

1420 FIFTH AVENUE, SUITE 3150

SEATTLE , WA 98101

206.223.1747

Hon. Ricardo S. Martinez

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

UNITED STATES OF AMERICA, )

)

Plaintiff, ) NO. CR 05-346 RSM

)

v. ) STIPULATION AND ORDER

) TO CONTINUE TRIAL DATE

ELIZABETH ANGOUS, )

)

Defendant. )

___________________________________)

It is stipulated by and between the United States of

America, by Assistant United States Attorney Susan Harrison, 

and defendant Elizabeth Angous, by her attorney Ralph Hurvitz,

that trial in this case may be continued from November 28,

2005 to March 27, 2006, with a new motions cut off date of

March 2, 2006.

A superseding indictment was recently returned against

Ms. Angous charging thirty three counts of bank fraud, four

counts of wire fraud, one count of fraud in relation to access

devices, one count of misuse of the social security number of

Case 2:05-cr-00346-RSM Document 37 Filed 11/18/05 Page 1 of 4
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RALPH HURVITZ

ATTORNEY

1420 FIFTH AVENUE, SUITE 3150

SEATTLE , WA 98101

206.223.1747

another, and three counts of aggravated identity theft. 

Counsel was recently appointed to substitute for Jennifer

Horwitz as counsel for Ms. Angous. Counsel requires

additional time in order to familiarize himself with the

extensive discovery material in this case. It may be possible

that with additional time, Ms. Angous may resolve her case

short of litigation of pretrial motions and trial.

The parties stipulate that the ends of justice served by

continuing the trial date outweigh any interests of the public

or of the defendant in a speedy trial as per 18 U.S.C.

§3161(c)(1). Ms. Angous has discussed her right to a speedy

trial with counsel, and will file a waiver of speedy trial

through April 1, 2006.

Dated this 16th day of November, 2005.

 s/Ralph Hurvitz

RALPH HURVITZ

Attorney for Defendant

WSBA 7365

1420 Fifth Avenue

Suite 3150

Seattle WA 98101

Tel: 206.223.1747

Fax: 206.467.1823

E-mail: ralph@hurvitz.com

 s/Susan Harrison

SUSAN HARRISON

Assistant United States Attorney

 700 Stewart Street

Suite 5220

STIPULATION AND ORDER-2

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RALPH HURVITZ

ATTORNEY

1420 FIFTH AVENUE, SUITE 3150

SEATTLE , WA 98101

206.223.1747

Seattle WA 98101

Tel: 206.553.7970

Fax: 206.553.2502

E-mail: sue.harrison@usdoj.gov

ORDER

The court has considered the stipulation of the parties

concerning a continuance of the trial date in this case. The

court finds that the ends of justice served by continuing the

trial date outweigh any interests of the public or of the

defendants in a speedy trial as per 18 U.S.C. §3161(c)(1).

Trial in this case is hereby continued to March 27, 2006. 

The new motions cut off date is March 2, 2006.

Dated this 18th day of November, 2005.

A

RICARDO S. MARTINEZ

UNITED STATES DISTRICT JUDGE

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RALPH HURVITZ

ATTORNEY

1420 FIFTH AVENUE, SUITE 3150

SEATTLE , WA 98101

206.223.1747

STIPULATION AND ORDER-3

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