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United States of America v. Camilo Reyes

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


December 8, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
CAMILO REYES, 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 hereby stipulate that the status conference in this case be continued from December 10, 2010, to January 28, 2011, at 9:00 a.m. The parties stipulate that the time between December 10, 2010, and January 28, 2011, 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, Mr. Reyes is a Spanish-speaking client who needs the assistance of an investigator who speaks Spanish to assist counsel in reviewing the discovery with Mr. Reyes including a video-taped confession which is in Spanish. Counsel is waiting for authorization for funds for investigation and will then meet with Mr. Reyes and his family to review the discovery with the Spanish-speaking investigator. Therefore the parties have stipulated to continue the status conference in this case. 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

TIM A. PORI

Attorney for Defendant CAMILO REYES

Date: December 8, 2010

Authorized 12/8/10

MICHAEL D. ANDERSON Assistant U.S. Attorney

[PROPOSED] ORDER

IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter is continued to January 28, 2011, at 9:00 a.m. before the Honorable Garland E. Burrell in courtroom number 10.

Dated: December 8, 2010

20101208

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