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United States v. Medina

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


March 19, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
EFRAIN MEDINA, ET AL, DEFENDANTS.

The opinion of the court was delivered by: Judge Hon. Garland E. Burrell, Jr.

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: 03/20/2009

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Ricardo Venegas, John R. Manning Esq., counsel for defendant Wendell Stewart, Daniel M. Davis, Esq., counsel for defendant Valerie White, William E. Bonham, Esq., counsel for defendant Aaron Potts, Timothy E. Warriner, Esq., and counsel for defendant Isauro Jauregui Catalan, Edward C. Bell, Esq., that the status conference presently set for March 20, 2009 be continued to May 8, 2009, at 9:00 a.m., thus vacating the presently set status conference.

Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code § 3161(h)(8)(B)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the requested continuance is based upon more time needed to investigate as well as Mr. Warriner being in trial) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, May 8, 2009.

IT IS SO STIPULATED.

Dated: March 18, 2009

JOHN R. MANNING Attorney for Defendant Ricardo Venegas

DANIEL M. DAVIS Attorney for Defendant Wendell Stewart

WILLIAM E. BONHAM Attorney for Defendant Valerie White

EDWARD C. BELL Attorney for Defendant Isauro Jauregui Catalan

TIMOTHY E. WARRINER Attorney for Defendant Aaron Potts

McGREGOR W. SCOTT United States Attorney

JILL M. THOMAS Assistant U.S. Attorney

[PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

GOOD CAUSE APPEARING, it is hereby ordered that the March 20, 2009 status conference be continued to May 8, 2009 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days.

THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T4 from the date of this order to May 8, 2009.

IT IS SO ORDERED.

GARLAND E. BURRELL, JR. United States District Judge

20090319

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