IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 10, 2010
UNITED STATES OF AMERICA,
GAULDRY T. ALMONTE-HERNANDEZ,
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2770
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from December 10, 2010 to December 17, 2010 at 9:00 a.m. They stipulate that the time between December 10, 2010 and December 17, 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
Dated: December 10, 2010
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