STIPULATION AND PROPOSED ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
It is hereby stipulated and agreed to between defendants Norman Mike, Alex ZavalaTapia, Jose Mendoza-Garcia and Miguel Abundez Mosqueda, by and through their respective counsel, Dwight M. Samuel, Benjamin Galloway, Gilbert Roque, and Clemente M. Jimenez and plaintiff United States of America, by and through Samuel Wong, Assistant United States Attorney, that the status conference presently set for Monday, January 11, 2010 be vacated and rescheduled for a status conference on Monday, March 22, 2010, at 8:30 a.m.
Defendants have requested additional discovery from the United States and additional time is necessary for the United States to obtain and produce the discovery, and defendants to review and investigate the new discovery. In addition, some of the new discovery may need to be translated from the Spanish language to the English language and additional time is needed to perform this work. Therefore all parties request that the Court continue the status conference to March 22, 2010. It is further stipulated and agreed by all parties that the period from the date of this stipulation, January 7, 2010, through and including March 22, 2010, be excluded in computing the time within which trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T-4 for preparation of defense counsel.
Respectfully submitted, Dated: January 7, 2010
DWIGHT M. SAMUEL Attorney for Defendant, Norman A. Mike
Gilbert Roque*fn1 Attorney for Defendant, Jose Mendoza-Garcia
Clemente M. Jimenez*fn2 Attorney for Defendant, Miguel Abundez Mosqueda
Benjamin D. Galloway*fn3 Attorney for Defendant, Alex Zavala-Tapia
BENJAMIN B. WAGNER United States Attorney
Samuel Wong*fn4 Assistant United ...