IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
April 29, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
JOSE OLIVERA ZAPIEN, ET.AL. DEFENDANT.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from May 3, 2010 to June 28, 2010 at 8:30 a.m. They stipulate that the time between May 3, 2010 and June 28, 2010 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
18 U.S.C. § 3161(h)(7)(B)(iv)and Local Code T-4. Specifically, all defense counsel need additional time to review the discovery provided and investigate the case. Prior to the last stipulation, the government had provided an additional 447 pages of discovery and 5 additional CD's containing translations and transcriptions of the wire recordings in this case, which continue to be reviewed by defense counsel. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
DATE: April 29, 2010
BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney MICHAEL PETRICK Attorney for Defendant Jose Olivera Zapien
GILBERT ROQUE Attorney for Defendant Ramiro Suarez
RUBEN MUNOZ Attorney for Defendant Adolfo Valencia Alvarez
OLAF HEDBERG Attorney for Defendant Jose Quintero Fernandez
CLEMENTE JIMENEZ Attorney for Defendant Jose Moreno Gutierrez
TIM PORI Attorney for Defendant Erik Aguilar Lara
CHRIS COSCA Attorney for Defendant Alejandro Moreno Gutierrez
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