IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 3, 2011
UNITED STATES OF AMERICA,
ANTONIO PEREZ AND JULIO RAMIREZ PEREZ,
The opinion of the court was delivered by: Judge: Hon. Oliver W. Wanger
Date: March 7, 2011 Time:9:00 a.m.
STIPULATION TO CONTINUE STATUS CONFERENCE AND ORDER THEREON
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, KAREN A. ESCOBAR, Assistant United States Attorney, counsel for plaintiff, DAVID A. TORRES, counsel for defendant Antonio Perez, and ERIC V. KERSTEN, Assistant Federal Defender, counsel for defendant Julio Ramirez Perez, that the date for status conference may be continued to March 7, 2011 at 9:00AM, or the soonest date thereafter that is convenient to the court. The date currently set for status conference is February 7, 2011. The requested new date is March 7, 2011.
This continuance is requested to allow additional time for defense investigation, and also to allow further negotiations in an attempt to reach a negotiated settlement in this matter.
The parties agree that the delay resulting from the continuance shall be excluded as necessary for effective defense preparation, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). For this reason, the ends of justice served by the granting of the requested continuance outweigh the interests of the public and the defendant in a speedy trial.
BENJAMIN B. WAGNER United States Attorney DATED: February 3, 2011 By /s/ Karen A. Escobar KAREN A. ESCOBAR Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender DATED: February 3, 2011 By /s/ Eric V. Kersten ERIC V. KERSTEN
Assistant Federal Defender Attorney for Defendant Julio Ramirez Perez DATED: February 3, 2011 /s/ David A. Torres DAVID A. TORRES Attorney for Defendant Antonio Perez ORDER IT IS SO ORDERED. The intervening period of delay is excluded in the interests of justice pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). IT IS SO ORDERED. Dated: February 3, 2011 /s/ Oliver W. Wanger emm0d6 UNITED STATES DISTRICT JUDGE
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