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United States v. Galvan

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


October 14, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
RAFAEL GALVAN DEFENDANT.

The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge

STIPULATION AND ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from October 15, 2009 to October 29, 2009 at 9:00 a.m. They stipulate that the time between October 15, 2009 and October 29, 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 the defendant 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, the defense is still performing investigation and reviewing discovery in this matter. Additionally, the parties are engaged in on-going plea negotiations that may resolve the matter short of trial. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

Respectfully Submitted,

LAWRENCE G. BROWN United States Attorney

DATE: October 14, 2009

By: HEIKO P. COPPOLA Assistant U.S. Attorney

DATE: October 14, 2009

Patrick K. Hanly*fn1 Attorney for Defendant

IT IS SO ORDERED.


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