The opinion of the court was delivered by: Judge Honorable John A. Mendez
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Heiko P. Coppola, Assistant United States Attorney, together with counsel for defendant Roberto Rodriguez, John R. Manning, Esq., counsel for defendant Martin Nevarez, Caro Marks, Esq., counsel for defendant Jose Lozano-Lopez, Hayes H. Gable, Esq., counsel for defendant Antonio Baldenegro, Dina L. Santos, Esq., counsel for defendant Jose Gutierrez, Michael B. Bigelow, Esq., and counsel for defendant Jesus Sandoval, Clemente M. Jimenez, Esq., that the status conference presently set for May 11, 2010 be continued to June 15, 2010, at 9:30 a.m., thus vacating the presently set status conference.
Defense counsel require additional time to review discovery as it relates to the plea agreements provided by the government, review those plea agreements with the defendants and perform additional investigation. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, June 15, 2010.
JOHN R. MANNING Attorney for Defendant Roberto Rodriguez
CARO MARKS Attorney for Defendant Martin Nevarez
HAYES H. GABLE Attorney for Defendant Jose Lozano-Lopez
DINA L. SANTOS Attorney for Defendant Antonio Baldenegro
MICHAEL B. BIGELOW Attorney for Defendant Jose Gutierrez
CLEM ENTE M. JIMENEZ Attorney for Defendant Jesus Sandoval
Lawrence Brown Acting United States Attorney
HEIKO P. COPPOLA Assistant U.S. Attorney JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant ROBERTO RODRIGUEZ
GOOD CAUSE APPEARING, it is hereby ordered that the May 11, 2010 status conference be continued to June 15, 2010 at 9:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be ...