The defendant, MOISES CASTRO, through his attorney ROBERT L. FORKNER, and the United States, through its counsel, Assistant United States Attorney KATHLEEN ANN SERVATIUS, hereby stipulate and request the following:
That the Court change the status conference in the above-captioned case from January 10, 2011, to February 7, 2011, at 9:00 a.m. for Status Conference.
The defense counsel has been unable to coordinate a visit with Mr. Castro to completely review the government's proposed plea agreement. The defendant has showed an express interest in signing the agreement and would like to review it with counsel once more before doing so. Defense counsel was unable to meet with Mr. Castro prior to January 10, 2011 due to Jury Trials, the holidays and the unavailability of an interpreter.
For these reasons, both parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from January 10, 2011 through February 7, 2011, for case resolution under 18 U.S.C. § 3161(h)(7)(B)(iv).
Respectfully submitted, January 5, 2011
ROBERT L. FORKNER Attorney for Defendant Dated: January 5, 2011 /s/ Kathleen Anne Servatius KATHLEEN ANNE SERVATIUS Assistant United States Attorney
IT IS SO ORDERED. For the reasons stated above, the Court finds that the needs of defense counsel to prepare outweigh the public and the defendants' interest in a speedy trial, and therefore the date, change of hearing, and exclusion of time are in the interest of justice.
CHIEF UNITED STATES DISTRICT JUDGE
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