STIPULATION AND [PROPOSED] ORDER
DATE: April 26, 2010 TIME: 8:30 a.m.
JUDGE: Hon. William B. Shubb
It is hereby stipulated and agreed to between the United States of America through MICHAEL ANDERSON, Assistant U.S. Attorney, and defendant, JUAN MANUEL RAMIREZ-DIAZ by and through his counsel, BENJAMIN GALLOWAY, Assistant Federal Defender, that the status conference set for Monday, March 29, 2010, be continued to Monday, April 26, 2010, at 8:30 a.m.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case. Speedy trial time is to be excluded from the date of this order through the date of the status conference set for April 26, 2010, pursuant to 18 U.S.C. §§ 3161 (h)(8)(B)(iv) [reasonable time to prepare] (Local Code T4).
DATED: March 24, 2010 Respectfully submitted, DANIEL J. BRODERICK Federal Defender BENJAMIN GALLOWAY Assistant Federal Defender Attorney for Defendant JUAN MANUEL RAMIREZ-DIAZ
DATED: March 24, 2010 BENJAMIN B. WAGNER United States Attorney Benjamin Galloway for MICHAEL ANDERSON Assistant U.S. Attorney Attorney for Plaintiff
Time is excluded from today's date through and including April 26, 2010, in the interests of justice pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) [reasonable time to prepare] and Local Code T4. The status conference set for Monday, March 29, 2010, is continued to Monday, April 26, 2010, at 8:30 a.m.
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