The opinion of the court was delivered by: Judge: Hon. William B. Shubb
STIPULATION AND (PROPOSED) ORDER CONTINUING STATUS CONFERNCE
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michael M. Beckwith, Assistant United States Attorney, together with counsel for defendant Uriel Ochoa-Espindola, Preciliano Martinez, Esq., counsel for defendant Jose Sergio Espindola, Mark J. Rosenblum, Esq., counsel for defendant Valentin Ramirez- Cardinez, Robert L. Forkner, Esq., counsel for defendant Rafael Arreola-Sahagun, Dina L. Santos, Esq., counsel for defendant Emiliano Vera-Gil, John R. Manning, Esq., counsel for defendant Jose Manuel Vera-Gil, Danny D. Brace, Esq., counsel for defendant Armando Espindola, John R. Durree, Jr., Esq., and counsel for defendant Luis Miguel-Rodrigues, Dan F. Koukol, Esq., that the status conference presently set for November 15, 2010 be continued to January 24, 2011, at 8:30 a.m., thus vacating the presently set status conference. Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code § 3161(h) (7) (B) (ii) and (iv) (continuity of counsel/ reasonable time for effective preparation) 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 January 24, 2011.
The parties are requesting more time to continue ongoing plea negotiations. 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).
PRECILIANO MARTINEZ Attorney for Defendant Uriel Ochoa-Espindola
John R. Manning for MARK ROSENBLUM Attorney for Defendant Jose Sergio Espindola
John R. Manning for ROBERT FORKNER Attorney for Defendant Valentin Ramirez-Cardinez
John R. Manning for DINA L. SANTOS Attorney for Defendant Rafael Arreola-Sahagun
John R. Manning for DANNY D. BRACE, JR. Attorney for Defendant Jose Manuel Vera-Gil
John R. Manning for DAN KOUKOL Attorney for Defendant Luis Miguel Orrutia-Rodrigues
John R. Manning for JOHN R. DUREE, JR. Attorney for Defendant Armando Espindola
Benjamin B. Wagner United States Attorney John R. Manning for MICHAEL M. BECKWITH Assistant United States Attorney
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 ...