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United States v. Ochoa-Espindola

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


June 17, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
URIEL OCHOA-ESPINDOLA ET AL., DEFENDANTS.

The opinion of the court was delivered by: Hon. William B. Shubb

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME

The parties request that the status conference currently set for June 21, 2010, be continued to August 23, 2010, and stipulate that the time beginning June 21, 2010, and extending through August 23, 2010, should be excluded from the calculation of time under the Speedy Trial Act. The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for each defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(ii) and (iv); Local Codes T2 and T4.

The parties are in the process of discussing and negotiating various pretrial dispositions. Each defendant will need time to consider any plea offer he or she may receive. Additionally, counsel for each defendant needs more time to review the discovery in this case, discuss that discovery with their respective clients, consider evidence that may affect the disposition of this case, and discuss with their clients how to proceed. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

Respectfully Submitted,

Dated: June 16, 2010

PRECILIANO MARTINEZ Attorney for defendant Uriel Ochoa-Espindola

MARK J. ROSENBLUM Attorney for defendant Jose Sergio Espindola

ROBERT L. FORKNER Attorney for defendant Valentin Ramirez-Cardinez

DINA L. SANTOS Attorney for defendant Rafael Arreola-Sahagun

JOHN RICHARD MANNING Attorney for defendant Emiliano Vera-Gil

DANNNY D. BRACE, Jr. Attorney for defendant Jose Manuel Vera-Gil

DWIGHT M. SAMUEL Attorney for defendant Hector Carretero-Flores

OLAF WILLIAM HEDBERG Attorney for defendant Brenda Meza-Rodrigues

DAN F. KOUKOL Attorney for defendant Luis Miguel Orrutia-Rodrigues

ORDER

The status conference in case number CR. S 09-380 WBS, currently set for June 21, 2010, is continued to August 23, 2010, and the time beginning June 21, 2010, and extending through August 23, 2010, is excluded from the calculation of time under the Speedy Trial Act. The Court finds that interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(ii) and (iv); Local Codes T2 and T4.

IT IS SO ORDERED.

20100617

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