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United States v. Zapien

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


June 24, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
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 June 28, 2010 to September 27, 2010 at 8:30 a.m. They stipulate that the time between June 28, 2010 and September 27, 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. Well over 1000 pages of discovery and 80 CD's containing video, audio recordings and photographs have been provided to the defense counsel to date. 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).

Respectfully Submitted,

BENJAMIN B. WAGNER United States Attorney

DATE: June 24, 2010

HEIKO P. COPPOLA Assistant U.S. Attorney

DATE: June 24, 2010

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

SO ORDERED.

20100624

© 1992-2010 VersusLaw Inc.



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