IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
April 8, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
CESAR RAMIREZ-ROSALES, DEFENDANT.
The opinion of the court was delivered by: Judge William B. Shubb
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE; EXCLUDING TIME
Date: April 12, 2010
IT IS HEREBY STIPULATED between the parties, Michael Anderson, Assistant United States Attorney, and Douglas J. Beevers, Assistant Federal Defender, attorney for defendant CESAR RAMIREZ-ROSALES, that the status conference of April 12, 2010 be vacated, and the matter be set for status conference on May 10, 2010 at 8:30 a.m.
The reason for the continuance is the Government has recently made a plea agreement available to the defendant. Additional time is needed for defense counsel to review the plea agreement 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 and agreed between the parties that the period from the signing of this Order, up to and including May 10, 2010 be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, for ongoing preparation of counsel.
Dated: April 8, 2010
DANIEL J. BRODERICK Federal Defender
DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant CESAR RAMIREZ-ROSALES
BENJAMIN B. WAGNER United States Attorney
MICHAEL ANDERSON Assistant U.S. Attorney
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for April 12, 2010 be continued to Monday, May 10, 2010 at 8:30am. Based on the representation of defense counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case would deny defendant reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including May 10, 2010, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4, to allow defense counsel time to prepare.
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