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United States v. Garcia-Perez

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


April 30, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
RAMON GARCIA-PEREZ, DEFENDANT.

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

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: May 26, 2009

It is hereby stipulated between the parties, Michael Anderson, Assistant United States Attorney, attorney for plaintiff, and Lauren D. Cusick, Assistant Federal Defender, attorney for defendant, RAMON GARCIA-PEREZ, that the status conference hearing date of May 4, 2009 be vacated and continued to May 26, 2009 at 8:30 a.m.

This continuance is requested as negotiations are continuing between the parties and additional time is needed for defense investigation.

It is further stipulated that the period from the date of this stipulation through and including May 26, 2009 should be excluded pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) and Local Code T4 based upon continuity of counsel and defense preparation.

Dated: April 30, 2009

Respectfully submitted,

DANIEL J. BRODERICK Federal Defender

LAUREN D. CUSICK Assistant Federal Defender Attorney for Defendant RAMON GARCIA-PEREZ

LAWRENCE G. BROWN Acting United States Attorney Lauren D. Cusick for MICHAEL ANDERSON Assistant U.S. Attorney per telephonic authorization

ORDER

The status conference is continued to May 26, 2009 at 8:30 a.m. The court finds that a continuance is necessary for the reasons stated above and further finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. Time is therefore excluded from the date of this order through May 26, 2009, pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv).

IT IS SO ORDERED.

20090430

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