IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 2, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
WENCESLAO GRIJALBA ROSALES, DEFENDANTS.
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
STIPULATION AND ORDER
The defendant, WENCESLAO GRIJALBA ROSALES, through his attorney ROBERT L. FORKNER, and the United States, through its counsel, Assistant United States Attorney DANIEL S. MCCONKIE, hereby stipulate and request the following:
That the Court change the status conference in the above-captioned case from December 4, 2009, to January 8, 2010, at 9:00 a.m. for Entry of Plea.
The government will be submitting a proposed plea agreement and defense counsel needs additional time to review the plea agreement with the defendant and a certified interpreter.
For these reasons, the parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from December 4, 2009 through January 8, 2010, for case resolution under 18 U.S.C. § 3161(h)(8)(B)(ii) and (iv) (local codes T2 and T4).
Dated: December 1, 2009 ROBERT L. FORKNER Attorney for Defendant Wenceslao Grijalba Rosales
Dated: December 1, 2009 DANIEL S. MCCONKIE Assistant United States Attorney
IT IS SO ORDERED.
For the reasons stated above, the Court finds that the needs of defense counsel to prepare outweigh the public and the defendants' interest in a speedy trial, and therefore the date, change of hearing, and exclusion of time are in the interest of justice.
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