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.
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 ...