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United States v. Flores-Rios

March 18, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOEL FLORES-RIOS, DEFENDANT.



The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED ORDER]

Date: March 19, 2010 Time: 9:00 a.m. Judge: Hon. Garland E. Burrell

IT IS HEREBY STIPULATED by the parties, through counsel, Michael D. Anderson, Assistant United States Attorney, and Michael Petrik, Jr., attorney for Mr. Flores-Rios, that the Court should vacate the status conference scheduled for March 19, 2010, at 9:00 a.m., and reset it for April 9, 2010, at 9:00 a.m.

Counsel for Mr. Flores-Rios requires the continuance in order to review the Pre-Plea Advisory Guideline Presentence Investigation Report and a proposed plea agreement with Mr. Flores-Rios.

It is further stipulated by the parties that the Court should exclude the period from the date of this order through April 9, 2010, when it computes the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act. The parties stipulate that the ends of justice served by granting Mr. Flores-Rios's request for a continuance outweigh the best interest of the public and Mr. Flores-Rios in a speedy trial, and that this is an appropriate exclusion of time for defense preparation within the meaning of 18 U.S.C. § 3161(h)(7)(A) and (B) (Local Code T4).

Dated: March 18, 2010

Respectfully submitted,

DANIEL BRODERICK Federal Defender

MICHAEL PETRIK, Jr. Assistant Federal Defender Attorneys for Defendant

Dated: March 18, 2010

BENJAMIN B. WAGNER United States Attorney

M. Petrik for Michael D. Anderson

MICHAEL D. ANDERSON Assistant ...


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