IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
March 30, 2011
UNITED STATES OF AMERICA,
JOSE PENA, ET.AL.
The opinion of the court was delivered by: Hon. John A. Mendez U.S. District Judge
STIPULATION AND ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from April 12, 2011 to June 14, 2011 at 9:30 a.m. They stipulate that the time between April 12, 2011 and June 14, 2011 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Specifically, all defense counsel need additional time to review the discovery already provided and to conduct further investigation of the case. The parties 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).
Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney DATE: March 30, 2011 By: HEIKO P. COPPOLA Assistant U.S. Attorney DATE: March 30, 2011 MICHAEL LONG Attorney for Defendant Jose Pena /s/ Matthew Beauchamp MATTHEW BEAUCHAMP Attorney for Defendant Leonardo Contreras /s/ Erin Radekin ERIN RADEKIN Attorney for Defendant Damian Cervantes /s/ Carl Larson CARL LARSON Attorney for Defendant Oscar Virrueta
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