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United States v. Ramirez

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


November 7, 2008

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HUBERT MARIO RAMIREZ ET AL., DEFENDANTS.

The opinion of the court was delivered by: Hon. William B. Shubb

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME

The parties request that the status conference currently set for November 10, 2008, be continued to February 23, 2009, and stipulate that the time beginning November 10, 2008, and extending through February 23, 2009, should be excluded from the calculation of time under the Speedy Trial Act. The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for each defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(8)(B)(iv); Local Code T4.

The parties are in the process of discussing and negotiating various pretrial dispositions. Each defendant will need time to consider any plea offer he may receive. Additionally, counsel for each defendant needs more time to review the discovery in this case, discuss that discovery with their respective clients, consider evidence that may affect the disposition of this case, and discuss with their clients how to proceed. The undersigned parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(8)(A).

Respectfully Submitted,

ORDER

The status conference in case number CR. S-08-0357 WBS, currently set for November 10, 2008, is continued to February 23, 2009, and the time beginning November 10, 2008, and extending through February 23, 2009, is excluded from the calculation of time under the Speedy Trial Act. For the reasons stated in the above stipulation, the Court finds that interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(8)(A).

IT IS SO ORDERED.

20081107

© 1992-2008 VersusLaw Inc.



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