IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 28, 2011
UNITED STATES OF AMERICA,
JOSE OLIVERA ZAPIEN, ET.AL.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from January 31, 2011 to April 4, 2011 at 8:30 a.m. They stipulate that the time between January 31, 2011 and April 4, 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, all defense counsel need additional time to review the discovery provided and investigate the case. Well over 2000 pages of discovery and 80 CD's containing video, audio recordings and photographs have been provided to the defense counsel to date. The government recently provided an approximately 1200 additional pages of discovery that defense counsel will need to review. 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
HEIKO P. COPPOLA Assistant U.S. Attorney
DATE: January 28, 2011 /s/ Michael Petrick
MICHAEL PETRICK Attorney for Defendant Jose Olivera Zapien GILBERT ROQUE Attorney for Defendant Ramiro Suarez RUBEN MUNOZ Attorney for Defendant Adolfo Valencia Alvarez OLAF HEDBERG Attorney for Defendant Jose Quintero Fernandez CLEMENTE JIMENEZ Attorney for Defendant Jose Moreno Gutierrez TIM PORI Attorney for Defendant Erik AguilarLara CHRIS COSCA Attorney for Defendant Alejandro Moreno Gutierrez
DATE: January 28, 2011
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