IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 7, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
GAULDRY T. ALMONTE-HERNANDEZ, DEFENDANT.
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from October 8, 2010 to October 29, 2010 at 9:00 a.m. They stipulate that the time between October 8, 2010 and October 29, 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, defense counsel is still reviewing discovery provided by the government and conducting his investigation. 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: October 7, 2010 HEIKO P. COPPOLA Assistant U.S. Attorney
DATE: October 7, 2010 JEFFREY STANIELS Attorney for Defendant
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