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United States v. Santiago

December 28, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOSE SANTIAGO, DEFENDANT.



The opinion of the court was delivered by: Judge: Hon. William B. Shubb

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: January 11, 2010

Time: 8:30 a.m.

It is hereby stipulated between the parties, Michael Anderson, Assistant United States Attorney, attorney for plaintiff and Douglas J. Beevers, Assistant Federal Defender, attorney for defendant, JOSE SANTIAGO, that the Status Conference hearing date of January 7, 2010 at 8:30 a.m. be vacated and a new Status Conference hearing date of January 11, 2010, at 8:30 a.m. be set.

The grounds for the continuance are that the parties are still negotiating a disposition, but have not finished verifying details in the pre-plea pre-sentence report. Defense counsel needs time to investigate and to review the offer with the defendant. The parties agree a continuance is necessary for this purpose, and agree to exclude time under the Speedy Trial Act accordingly.

It is further stipulated that the period from January 7, 2009, through and including January 11, 2010, should be excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 based upon continuity of counsel and defense preparation.

Dated: December 28, 2009

Respectfully submitted,

DANIEL J. BRODERICK Federal Defender

DOUGLAS J. BEEVERS Assistant Federal Defender Attorney for Defendant JOSE SANTIAGO

Dated: December 28, 2009

BENJAMIN B. WAGNER United States Attorney

MICHAEL ANDERSON Assistant ...


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