IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 5, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
WENCESLAO GRIJALBA ROSALES, DEFENDANTS.
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
AMENDED STIPULATION AND PROPOSED ORDER
The defendant, WENCESLAO GRIJALBA ROSALES, through his attorney ROBERT L. FORKNER, and the United States, through its counsel, Assistant United States Attorney DANIEL S. MCCONKIE, hereby stipulate and request the following:
That the Court change the status conference in the above-captioned case from April 23, 2010, to June 18, 2010, at 9:00 a.m. for Entry of Plea.
The defense counsel received a proposed plea agreement and reviewed the plea agreement with the defendant and a certified interpreter. The defendant signed the plea agreement. However, subsequent changes have been made to the plea agreement. Defense counsel will not be able to review the changes with the defendant and a certified interpreter before the currently scheduled court date.
For these reasons, both parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from April 23, 2010 through June 18, 2010, for case resolution under 18 U.S.C. § 3161(h)(7)(B)(iv).
Respectfully submitted, Dated: April 20, 2010 ROBERT L. FORKNER Attorney for Defendant
Dated: April 20, 2010 DANIEL S. MCCONKIE Assistant United States Attorney
IT IS SO ORDERED.
For the reasons stated above, the Court finds that the needs of defense counsel to prepare outweigh the public and the defendants' interest in a speedy trial, and therefore the date, change of hearing, and exclusion of time are in the interest of justice.
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