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United States of America v. Felipe Maramba

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


December 14, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
FELIPE MARAMBA
DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell

Date: February 18, 2011 Time: 9:00 a.m.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

THE PARTIES STIPULATE, through counsel, Michelle Rodriguez, Assistant United States Attorney, and Courtney Fein, Assistant Federal Defender, attorney for Felipe Maramba, that the Court should vacate the status conference scheduled for December 17, 2010, at 9:00 a.m., and reset it for February 18, 2011, at 9:00 a.m.

Counsel for the defendant requires further time to review discovery, discuss the contents of the discovery with her client, and has not yet received a probation report.

The parties further stipulate that the Court should exclude the period from the date of this order through February 18, 2011, when it computes the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act. The parties stipulate that the ends of justice served by granting the defendant's request for a continuance outweigh the best interest of the public and the defendant in a speedy trial, and that this is an appropriate exclusion of time for defense preparation within the meaning of 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) (Local Code T4). Dated: December 13, 2010 Respectfully submitted,

DANIEL BRODERICK Federal Defender C. Fein COURTNEY FEIN Assistant Federal Defender Dated: December 13, 2010 BENJAMIN B. WAGNER United States Attorney C.Fein for MICHELLE RODRIGUEZ Assistant U.S. Attorney

ORDER

IT IS SO ORDERED. The status conference is continued to February 18, 2011 at 9:00 a.m. The court finds that a continuance is necessary for the reasons stated above, and further finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. Time is therefore excluded from the date of this order through February 18, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).

GARLAND E. BURRELL, JR. United States District Judge

20101214

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