IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 10, 2011
UNITED STATES OF AMERICA,
The opinion of the court was delivered by: Robert M. Holley
MOTION TO CONTINUE STATUS
CONFERENCE, STIPULATION, AND PROPOSED ORDER THEREON
Reasons for Motion to Continue The parties stipulate to a continuance in the above-captioned case. The defense has recently provided discovery to the United States, and the United States needs additional time to consider and evaluate that information, conduct follow-up, and communicate with defense counsel regarding a possible resolution. The parties request that the status conference presently set for February 14, 2011 at 8:30 a.m. be continued to Monday, March 7, 2011 at 8:30 a.m..
Stipulation The parties, through their respective counsel, stipulate that the status conference presently set for February 14, 2011 at 8:30a.m. be continued to Monday, March 7, 2011 at 8:30 a.m.. The parties further 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). The parties further stipulate that all time included in this continuance be excluded under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) for defense preparation and gathering of materials which may affect a possible plea negotiation. (Local Code T4).
Counsel for Mr. Ramirez BENJAMIN B. WAGNER United States Attorney By, JOHN K. VINCENT Assistant U.S. Attorney
GOOD CAUSE APPEARING, the calendaring change for a further status conference, as set forth above, with the stipulated exclusion of time under the Speedy Trial Act (18 U.S.C. § 3161) IS SO ORDERED. Dated: February 11, 2011
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