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United States of America v. Martin Nevarez

December 1, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MARTIN NEVAREZ, ET AL, DEFENDANTS. )



The opinion of the court was delivered by: Judge: Honorable John A. Mendez

STIPULATION AND ORDER CONTINUING STATUS CONFERENCE

IT IS HEREBY stipulated between the United States of America through its undersigned

counsel, Heiko P. Coppola, Assistant United States Attorney, together with counsel for defendant Roberto Rodriguez, John R. Manning, Esq., counsel for defendant Jose Lozano-Lopez, Hayes H.

Gable, Esq., counsel for defendant Antonio Baldenegro, Dina L. Santos, Esq., counsel for defendant Jose Gutierrez, Michael B. Bigelow, Esq., and counsel for defendant Jesus Sandoval, Clemente M. Jimenez, Esq., that the status conference presently set for December 7, 2010 be continued to January 18, 2011, at 9:30 a.m., thus vacating the presently set status conference.

Defense counsel require additional time to review discovery as it relates to the plea agreements provided by the government, review those plea agreements with the defendants and perform additional investigation. Therefore, the parties stipulate that the ends of justice are served by the Court excluding time from the date of the filing of the order until the date of the status conference, January 18, 2011, taking into account the exercise of due diligence. 18 U.S.C.

3161(h)(7)(B)(iv) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4. Counsel for the parties further stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A).

IT IS SO STIPULATED.

/s/ John R. Manning JOHN R. MANNING Attorney for Defendant Roberto Rodriguez

Dated: December 1, 2010 /s/ Hayes H. Gable HAYES H. GABLE Attorney for Defendant Jose Lozano-Lopez

Dated: December 1, 2010 /s/ Dina L. Santos DINA L. SANTOS Attorney for Defendant Antonio Baldenegro

Dated: December 1, 2010 /s/ Michael B. Bigelow MICHAEL B. BIGELOW Attorney for Defendant Jose Gutierrez

Dated: December 1, 2010 /s/ Clemente M. Jimenez CLEM ENTE M. JIMENEZ Attorney for Defendant Jesus Sandoval

Dated: December 1, 2010 Benjamin B. Wagner United ...


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