The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
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 RICARDO VENEGAS
STIPULATION AND [PROPOSED ORDER] CONTINUING STATUS CONFERENCE Judge: Honorable Garland E. Burrell, Jr.
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 Ricardo Venegas, John R. Manning, Esq., counsel for defendant Wendell Stewart, Candace A. Fry, Esq., counsel for defendant Valerie White, William E. Bonham, Esq., and counsel for defendant Isauro Jauregui Catalan, Edward C. Bell, Esq., that the status conference presently set for March18, 2011 be continued to April 8, 2011, at 9:00 a.m., thus vacating the presently set status conference.
Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code§ 3161(h)(7)(B)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the continuance is requested to allow more time for defense preparation and possible negotiations for resolution) 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 8, 2011.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. WENDALL STEWART, et al., Defendants.
[PROPOSED] ORDER TO CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the March 18, 2011 status conference be continued to April 8, 2011 at 9:00 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. THEREFOR IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161 (h) (7) (B) (iv) and Local Code T4 from the date of this order to April 8, 2011.
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