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United States of America v. Amador Eli Rosales

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


December 14, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
AMADOR ELI ROSALES, ET AL., DEFENDANTS.

The opinion of the court was delivered by: Judge: Honorable William B. Shubb

JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant MICHAEL LEONARD LOVATO

STIPULATION AND [PROPOSED ORDER] CONTINUING STATUS CONFERENCE

Defense counsel requires additional time to review the voluminous discovery and perform investigation. Therefore, counsel for the parties 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) (continuity of counsel/ reasonable time for effective preparation) 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, February 7, 2011.

IT IS SO STIPULATED.

Dated: December 9, 2010 JOHN R. MANNING Attorney for Defendant Michael Leonard Lovato

Dated: December 9, 2010 KELLY BABINEAU Attorney for Defendant Michael Valentino Lovato

Dated: December 9, 2010 DANNY D. BRACE, JR. Attorney for Defendant Jonathan Gonzalez

Dated: December 9, 2010 JAMES P. CHANDLER Attorney for Defendant Andre Kovacs

Dated: December 9, 2010 MICHAEL L. CHASTAINE Attorney for Defendant Amador Eli Rosales

Dated: December 9, 2010 DONALD P. DORFMAN Attorney for Defendant Nicole Garcia

Dated: December 9, 2010 DAN F. KOUKOL Attorney for Defendant Tony Rosales

Dated: December 9, 2010 MARK J. REICHEL Attorney for Defendant Adrianna Cano

Dated: December 9, 2010 TIMOTHY E. WARRINER Attorney for Defendant Derick Noble Dated: December 9, 2010 Benjamin B. Wagner United States Attorney by: 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 Attorney for Defendant MICHAEL LEONARD LOVATO

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

No. CR-S-10-0437 WBS

UNITED STATES OF AMERICA, Plaintiff, v. AMADOR ELI ROSALES, et al., Defendants.

ORDER TO CONTINUE STATUS CONFERNCE

GOOD CAUSE APPEARING, it is hereby ordered that the December 7, 2010 status conference be continued to February 7, 2011 at 8:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161(h)(7)(A) and Local Code T4 from the date of this order to February 7, 2011.

IT IS SO ORDERED.

20101214

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