IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
September 29, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
MARIA HERNANDEZ, DEFENDANT.
STIPULATION AND ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from September 29, 2009 to October 27, 2009 at 9:15 a.m. They stipulate that the time between September 29, 2009 and October 27, 2009 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for defendant Maria Hernandez may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Specifically, a plea agreement has been provided to defense counsel. The government and the defense counsel are in continuing negotiations about the terms of that plea agreement. It is anticipated that a final plea agreement incorporating new, negotiated terms will be provided to defense counsel shortly and that defense counsel will need additional time to review the new plea agreement with defendant Maria Hernandez.
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)(7)(A).
DATE: September 24, 2009
IT IS SO ORDERED.
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