IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
September 10, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
JORGE REYES, ET. AL., DEFENDANTS.
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
STIPULATION AND PROPOSED ORDER
Hon. Garland E. Burrell, Jr.
Date: October 15, 2010 Time: 9:00 a.m.
Defendant Jorge Reyes, through his attorney John Balazs, and the United States, through its attorney Assistant U.S. Attorney Michael Beckwith, hereby stipulate and request that the Court continue the status conference in the above-captioned case from September 10, 2010 to October 15, 2010, at 9:00 a.m.
The reason for this request is that defense counsel needs additional time to prepare, including reviewing voluminous discovery, wiretap affidavits, and audio recordings with the defendant. For these reasons, the parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from September 10, 2010 through October 15, 2010, for defense preparation under 18 U.S.C. § 3161(h)(7)(B)(iv) (local code T4) and complexity under 18 U.S.C. § 3161(h)(7)(B)(ii) (local code T2). Time has previously been excluded on these grounds through September 10, 2010. The parties also stipulate that the interest of justices served by granting this continuance outweigh the best interest of the public and the defendants in a speedy trial.
18 U.S.C. § 3161(h)(7)(A).
Respectfully submitted, Dated: September 10, 2010 /s/ John Balazs JOHN BALAZS Attorney for Defendant JORGE REYES BENJAMIN B. WAGNER U.S. Attorney
Dated: September 10, 2010 MICHAEL M. BECKWITH Assistant U.S. Attorney
IT IS SO ORDERED.
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