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United States of America v. Amador Eli Rosales

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


February 7, 2011

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

STIPULATION AND ) [PROPOSED ORDER] CONTINUING STATUS CONFERENCE

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Michael Leonard Lovato, John R. Manning, Esq., counsel for defendant Michael Valentino Lovato, Kelly Babineau, Esq., counsel for defendant Jonathan Gonzalez, Danny D. Brace, Jr., Esq., counsel for defendant Andre Kovacs, James P. Chandler, Esq., counsel for defendant Amador Eli Rosales, Michael L. Chastaine, Esq., counsel for defendant Nicole Garcia, Donald P. Dorfman, Esq., counsel for defendant Tony Rosales, Dan F. Koukol, Esq., counsel for defendant Adrianna Cano, Mark J. Reichel, Esq., and counsel for defendant Derick Noble, Timothy E. Warriner, Esq., that the status conference presently set for February 7, 2011 be continued to April 18, 2011, at 8:30 a.m., thus vacating the presently set 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, April 18, 2011.

IT IS SO STIPULATED.

Dated: February 2, 2011 JOHN R. MANNING Attorney for Defendant Michael Leonard Lovato

Dated: February 2, 2011 KELLY BABINEAU Attorney for Defendant Michael Valentino Lovato

Dated: February 2, 2011 DANNY D. BRACE, JR. Attorney for Defendant Jonathan Gonzalez

Dated: February 2, 2011 JAMES P. CHANDLER Attorney for Defendant Andre Kovacs

Dated: February 2, 2011 MICHAEL L. CHASTAINE Attorney for Defendant Amador Eli Rosales

Dated: February 2, 2011 DONALD P. DORFMAN Attorney for Defendant Nicole Garcia

Dated: February 2, 2011 DAN F. KOUKOL Attorney for Defendant Tony Rosales

Dated: February 2, 2011 MARK J. REICHEL Attorney for Defendant Adrianna Cano

Dated: February 2, 2011 TIMOTHY E. WARRINER Attorney for Defendant Derick Noble

Dated: February 2, 2011 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 February 7, 2011 status conference be continued to April 18, 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 April 18, 2011.

IT IS SO ORDERED.

20110207

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