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United States v. Gonzalez

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


September 4, 2008

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JORGE ARMANDO GONZALEZ, DEFENDANT.

STIPULATION RE: CONTINUANCE OF STATUS CONFERENCE AND TO EXCLUDE TIME; [PROPOSED] ORDER

The defendant, through his counsel of record and plaintiff, through its counsel of record, hereby stipulate that the Status Conference in the above-entitled matter, presently set for September 8, 2008 may be continued to October 14, 2008 8:30 A.M.

This stipulation is entered into at the request of the defendant as his counsel will be unavailable on the date presently set for Status Conference, to allow the defense to obtain a criminal history report and for the parties to continue to pursue and discuss plea negotiations.

The parties further stipulate that the time from September 8, 2008 to October 14, 2008 is excludable under the Speedy Trial Act (18 USC § 3161 et seq) and in particular, sections 18 USC §§ 3161(h)(8)(B)(i) and 3161 (h)(8)(B)(iv) to allow for adequate preparation and continuity of counsel and further that the ends of justice outweigh the public's interest in a speedy trial.

It is so stipulated.

Scott S. Furstman

Dated: September 4, 2008

SCOTT S. FURSTMAN Attorney for Defendant, Jorge Armando Gonzalez

Dated: September 4, 2008

ELLEN V. ENDRIZZI Assistant U.S. Attorney per telephonic authority

ORDER

Good cause appearing and the parties having stipulated thereto, it is ordered that the Status Conference presently set for September 8, 2008 is continued to October 14, 2008 at 8:30 a.m. It is further ordered that the time between September 8, 2008 and October 14, 2008, is excludable under 18 USC §§ 3161 (h)(8)(B)(i) and (iv) to allow for adequate preparation and continuity of counsel and that the ends of justice outweigh the public's interest in a speedy trial.

It is so ordered.

20080904

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