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United States v. Reyes

September 18, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JORGE ALBERT REYES, ET AL., DEFENDANTS.



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

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

The parties request that the status conference currently set for September 18, 2009, be continued to October 23, 2009, and stipulate that the time beginning September 18, 2009, and extending through October 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 the various plea offers in this case. Each defendant will need time to consider his or her offer in light of the discovery. As such, the attorneys for each defendant need more time to review the discovery in this case, discuss that discovery with their respective clients, consider new evidence that may affect the disposition of this case, conduct necessary legal research and investigation, and then discuss with their clients how to proceed. The 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).

Attempts were made to contact defense counsel for defendant, Juan Madrigal Rizo, with respect to this case and this continuance request. Sharon Goin legal assistant to the undersigned Assistant U.S. Attorney left a voice mail and an e-mail requesting a continuance of this matter with no response.

Respectfully Submitted,

LAWRENCE G. BROWN United States Attorney

Dated: September 16, 2009

By: MICHAEL M. BECKWITH Assistant U.S. Attorney

Dated: September 16, 2009

By: MATTHEW C. BOCKMON Attorney for defendant Adam Pablo Reyes

Dated: September 16, 2009

By: MICHAEL A. BRUSH Attorney for defendant Juan Gabriel Alvarez

Dated: September 16, 2009

By: CLARENCE EMMETT MAHLE Attorney for defendant Juan ...


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