Pursuant to plea negotiations, Defendant has agreed to enter a plea to Count Six, to wit: Penal Code Section

STATEMENT OF THE CASE

On February 27th, 2017, Defendant was charged by way of indictment in case

STK-CR-FE-2017-2704, to wit:

• Count 1: Section 424(a)(1)
• Count 2: Section 504
• Count 3: Section 487(a)
• Count 4: 186.10(c)(1)(A)
• Count 5: Section 424(a)(3)
• Count 6: 487(a)

One December 15th, 2017, a trial date was set for April 17, 2018.

At the March 26th readiness conference, an in-chambers conference was held among counsels for defense and the prosecution. After the conference, the defense requested that the trial date of April 17th, 2018 be vacated. The People, conceding good cause, voiced no opposition.

Subsequently, a new jury trial date was picked for November 6, 2018. In the interim, a new and separate complaint was filed on September 4th against Defendant (STK-CR-FECOD-2018-0011200).

Later, on October 16, the November trial date was vacated due to the parties’ scheduling conflicts and the court’s obligation in a time-not-waived special circumstances murder trial.

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