The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY stipulated between the UNITED STATES OF AMERICA through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with counsel for defendant Miguel Valencia, John R. Manning, Esq., that the status conference presently set for October 8, 2010 be continued to November 12, 2010 at 9:00 a.m., thus vacating the presently set status conference. Counsel for both parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code 3161 (h) (7) (B) (iv) (continuity of counsel/reasonable time for effective preparation, specifically, the requested continuance is based upon the need for further plea negotiation) 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, November 12, 2010.
JOHN R. MANNING Attorney for Defendant Miguel Valencia
Benjamin B. Wagner United States Attorney JASON HITT Assistant U.S. Attorney
JOHN R. MANNING (SBN 220874) LAW OFFICE OF JOHN R. MANNING 1111 "H" Street, Suite 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant MIGUEL VALENCIA
[PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
GOOD CAUSE APPEARING, it is hereby ordered that the October 8, 2010 status conference be continued to November 12, 2010 at 9:00 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 to for effective preparation exceeds the public interest in a trial within 70 days.
THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161 (h) (7) (B) (iv) and Local Code T4 from the date of this order to November 12, 2010.
GARLAND E. BURRELL, JR. United States ...