The opinion of the court was delivered by: Judge: Hon. William B. Shubb
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 CR-S-09-380 WBS Fax (916) 447-0931 Attorney for Defendant EMILIANO VERA-GIL
STIPULATION AND (PROPOSED) ORDER CONTINUING STATUS CONFERNCE Date: May 16, 2011 Time: 8:30 a.m.
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michael M. Beckwith, Assistant United States Attorney, together with counsel for defendant Uriel Ochoa-Espindola, Preciliano Martinez, Esq., counsel for defendant Jose Sergio Espindola, Mark J. Rosenblum, Esq., counsel for defendant Valentin Ramirez- Cardinez, Robert L. Forkner, Esq., counsel for defendant Rafael Arreola-Sahagun, Dina L. Santos, Esq., counsel for defendant Emiliano Vera-Gil, John R. Manning, Esq., counsel for defendant Jose Manuel Vera-Gil, Danny D. Brace, Esq., counsel for defendant Armando Espindola, John R. Durree, Jr., Esq., and counsel for defendant Luis Miguel-Rodrigues, Dan F. Koukol, Esq., that the status conference presently set for April 4, 2011 be continued to May 16, 2011, at 8:30 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) (ii) and (iv) (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 May 16, 2011.
The parties are requesting more time to continue ongoing plea negotiations. Each defendant will need time to consider any plea offer he or she may receive. Additionally, counsel for each defendant needs more time to review the discovery in this case, discuss that discovery with their respective clients, consider evidence that may affect the disposition of this case, and discuss with their clients how to proceed. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161 (h) (7) (A).
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. URIEL OCHOA-ESPINDOLA et al., Defendants.
ORDER TO ) CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the April 4, 2011 status conference be continued to May 16, 2011 at 8:30 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 May 16, 2011.
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