Timothy E. Warriner (SB#166128) Attorney at Law 813 6th St., Suite 450 Sacramento, CA 95814 (916) 443-7141 Attorney for defendant, Rafael Aguilar
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, defendant, Gerardo Rangel, by and through his counsel, Clemente M. Jimenez, defendant Rafael Aguilar, by and through his counsel, Timothy E. Warriner, and defendant, Jose Cobian, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the current status conference date of February 28, 2011, and to continue said status conference to April 11, 2011, at 8:30 a.m., in the courtroom of the Honorable William B. Shubb.
It is further agreed and stipulated that time shall continue to be excluded pursuant to the Speedy Trial Act for the purpose of continued defense preparation and ongoing plea negotiation. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4. Counsel are continuing to engage in plea negotiation, as well as trial preparation and investigation, and additional time is necessary for the attorneys to meet with the prosecution and to confer with the clients.
For the reasons set forth in the accompanying stipulation, the status conference as to defendants Rangel, Cobian, and Aguilar, now set for February 28, 2011 is vacated, and the matter is continued to April 11, 2011 at 8:30 a.m. Time continues to be excluded through April 11, 2011 pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 for the purpose of defense preparation.
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