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United States v. Aguirre-Valdes

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


September 18, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JESUS AGUIRRE-VALDES DEFENDANTS.

The opinion of the court was delivered by: Honorable Marilyn Hall Patel

PARTIES' STIPULATION AND PROPOSED ORDER REQUESTING CONTINUANCE OF STATUS CONFERENCE

The parties stipulate and agree, and the Court finds and holds, as follows:

1. The parties are currently scheduled to appear before this court on Monday, September 21, 21 2009 for status. The parties, however, request a continuance for this status date.

2. While most of the discovery in this matter has been provided, it is still ongoing. Discovery should be completed by September 28, 2009. Counsel for the defendant will require time to review the outstanding discovery which consists of recorded telephone conversations in the Spanish language.

3. Accordingly, the parties request that the court continue this matter until October 26, 2009. The parties stipulate that the time between September 21, 2009 and October 26, 2009, shall be excluded from the period of time within which the speedy trial must commence under the Speedy Trial Act, 18 U.S.C. §3161 et. seq., pursuant to Title 18, United States Code, Section 3 3161(h)(7)(A), since counsel for the defendant requires additional discovery, time to review that discovery and to effectively prepare the matter. It is stipulated that the ends of justice outweigh the best interest of the public and defendants in a speedy trial and the denial of the stipulation to continue the status hearing would unreasonably 7 deny the defendants reasonable time necessary for effective preparation of the defense.

SO STIPULATED.

Dated: September 16, 2009

Respectfully submitted,

SUSAN R. JERICH Assistant United States Attorney

Shana Keating Attorney for Jesus Aguirre Valdes

SO ORDERED.

20090918

© 1992-2009 VersusLaw Inc.



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