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United States of America v. Maria Del Rocio Arceo-Rangel

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


February 2, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MARIA DEL ROCIO ARCEO-RANGEL, ET AL., DEFENDANTS.

The opinion of the court was delivered by: Judge: Honorable Kimberly J. Mueller

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 CRUZ MANZO-GONZALEZ

STIPULATION AND ORDER CONTINUING STATUS CONFERENCE

IT IS HEREBY stipulated between the UNITED STATES OF AMERICA through its undersigned counsel, Samuel Wong, Assistant United States Attorney, together with counsel for defendant Maria Del Rocio Arceo-Rangel, Michael D. Long, Esq., counsel for defendant Erica Beatriz Martinez-Rangel, Hayes H. Gable, III, Esq., counsel for defendant Martin Garcia-Chavez, Michael B. Bigelow, Esq., counsel for defendant Isidro Gutierrez-Valencia, Dina L. Santos, Esq., counsel for defendant Cruz Manzo-Gonzalez, John R. Manning, Esq., counsel for defendant Alfredo Gallardo-Sosa, Jesse Ortiz, Esq., counsel for defendant Luis Renee Estrada Castanon, Michael E. Hansen, Esq., counsel for defendant Walter Marcuicio Lopez-Perez, Julia Vera, Esq., counsel for defendant Gumersindo Perez-Herrera, Preeti K. Bajwa, counsel for defendant Jorge Heriberto Andrade-Torres, Kirk McAllister, Esq., counsel for defendant Ricardo Castellanos-Cordova, Clemente M. Jimenez, Esq., counsel for defendant Jesus Munoz-Castanon, Carl E. Larson, Esq., and counsel for defendant Pedro Gutierrez-Valencia, James R. Greiner, Esq., hereby agree and stipulate that the status conference presently set for February 3, 2011 be continued to March 17, 2011, at 10:00 a.m., thus vacating the presently set status conference.

Further, all of the parties, the United States of America and all of the defendants as stated above, hereby agree and stipulate that time under the Speedy Trial Act should be excluded under Title 18, United States Code Section 3161(h)(7)(A) and (B)(ii) and (iv), corresponding to Local code T-2 (unusual and complex case) and Local Code T-4 (to allow defense counsel time to prepare) from the date of the parties' stipulation, February 2, 2011, to and including Thursday March 17, 2011.

PROCEDURAL STATUS OF THE CASE

On September 10 and 17, 2009, the government filed a criminal complaint against all defendants. (See Docket Entries #1 and 1)

On September 18, 2009, the government filed an Indictment charging twelve (12) defendants in Count 1 (conspiracy to manufacture at least 1,000 marijuana plants, Title 21, U.S.C. Sections 846 and 841 (a)(1)), Count 2 (manufacture of at least 1,000 marijuana plants, Title 21, U.S.C. Section 841 (a)(1)), and Count 3 (possession and discharge of a firearm in furtherance of a drug trafficking crime), Title 18, U.S.C. Section 924 (c)(1)(A)(i) and (iii)), and charging one defendant in Count 4 (accessory after the fact, Title 18, U.S.C. Section 3) and a Forfeiture Allegation against twelve (12) of the defendants (Title 21, U.S.C. Section 853(a), Title 18, U.S.C. Section 924(d)(1) and Title 28, U.S.C. Section 2461 (c)).

TIME EXCLUDED UNDER THE SPEEDY TRIAL ACT

The parties (the government and all thirteen (13) defendants) agree and stipulate that with the voluminous discovery, the number of defendants involved in the case (13), the complex legal issues involved in the case and the time needed by all defendants (13) to review all of the discovery produced by the government to date, it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in § 3161. In addition, the parties stipulate and agree that the continuance requested herein is necessary to provide defense counsel reasonable time to prepare their respective clients' defenses taking into account due diligence and that the interests of justice in granting this reasonable request for a continuance outweighs the best interests of the public and defendants for a speedy trial in this case, pursuant to Title 18, United States Code, Section 3161(h)(7)(A) and (B)(ii) and (iv), corresponding to Local Code T-2 (unusual and complex case) and Local Code T-4 (to allow defense counsel time to prepare).

Respectfully submitted:

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 CRUZ MANZO-GONZALEZ

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

UNITED STATES OF AMERICA, Plaintiff, v. MARIA DEL ROCIO ARCEO-RANGEL, et al., Defendants.

No. 2:09-cr-00407 KJM

ORDER TO CONTINUE STATUS CONFERNCE

The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. Based on the stipulation of the parties and the recitation of facts contained therein, the Court finds that this case is unusual and complex and that it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in 18 U.S.C. § 3161. In addition, the Court specifically finds that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.

The Court orders that the time from the date of the parties' stipulation, February 2, 2011, to and including March 17, 2011, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(ii) and (iv), and Local Codes T2 (unusual and complex case) and T4 (reasonable time for defense counsel to prepare). It is further ordered that the February 3, 2011, status conference shall be continued until March 17, 2011, at 10:00 a.m.

IT IS SO ORDERED.

20110202

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