The opinion of the court was delivered by: Judge: Honorable 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, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Ricardo Venegas, John R. Manning, Esq., counsel for defendant Wendell Stewart, Candace A. Fry, Esq., counsel for defendant Valerie White, William E. Bonham, Esq., and counsel for defendant Isauro Jauregui Catalan, Edward C. Bell, Esq., that the status conference presently set for December 3, 2010 be continued to February 4, 2011, at 9:00 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)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the continuance is requested to allow more time for defense preparation and possible negotiations for resolution) 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,
Dated: December 1, 2010 /s/ John R. Manning JOHN R. MANNING Attorney for Defendant Ricardo Venegas
Dated: December 1, 2010 /s/ Candace A. Fry CANDACE A. FRY Attorney for Defendant Wendell Stewart
Dated: December 1, 2010 /s/ William E. Bonham WILLIAM E. BONHAM Attorney for Defendant Valerie White
Dated: December 1, 2010 /s/ Edward C. Bell EDWARD C. BELL Attorney for Defendant Isauro Jauregui Catalan
Dated: December 1, 2010 Benjamin B. Wagner United States Attorney
by: /s/ Jill M. Thomas JILL M. THOMAS Assistant U.S. Attorney
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 ...