UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
March 27, 2009
UNITED STATES OF AMERICA PLAINTIFF,
DANIEL HERNANDEZ, DEFENDANT.
STIPULATION AND [PROPOSED] ORDER CONTINING STATUS CONFERENCE AND EXCLUDING TIME
It is hereby stipulated and agreed to between the United States of America through Jill Thomas, Assistant United States Attorney, and defendant, DANIEL HERNANDEZ, by and through his counsel, Lindsay Anne Weston, that the status conference in this matter currently scheduled for March 27, 2009, at 9:00 a.m. be continued to May 8, 2009, at 9:00
The basis for this continuance is that defense counsel requests additional time to complete investigation, with a newly retained investigator, on a possible pre-trial motion to suppress the evidence which is necessary to competent representation of Mr. Hernandez.
IT IS FURTHER STIPULATED that the period from March 27, 2009, (the date currently set for the status conference) through and including May 8, 2009, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) and Local Code T4 for continuity and preparation of counsel.
Dated: March 25, 2009
LINDSAY ANNE WESTON Attorney for Defendant DANIEL HERNANDEZ
LAWRENCE G. BROWN United States Attorney
Lindsay Weston for JILL THOMAS Assistant United States Attorney Per telephonic authorization
IT IS SO ORDRED.
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