BENJAMIN B. WAGNER United States Attorney JILL M. THOMAS Assistant U.S. Attorney 501 "I" Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2790
STIPULATION AND [PROPOSED] ORDER RESETTING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Jill M. Thomas, Assistant United States Attorney, defendant Gerardo Rangel, through his counsel of record, Clemente Jimenez, Esq., and defendant Jose Cobian, through his counsel of record, Erin Radekin, Esq., hereby stipulate and agree that the status conference set for July 18, 2011, be continued to August 8, 2011, at 8:30 a.m.
The parties need additional time for preparation. Therefore, the parties have agreed and respectfully request that the Court set the date of August 8, 2011, at 8:30 a.m., for the status conference.
Accordingly, the parties stipulate that time be excluded pursuant to 18 U.S.C. § 3161(h)(1)(F) and Local Code T4, United States Code section 3161(h)(7)(B)(iv), to give the defendants time to further review the discovery and to adequately prepare IT IS SO STIPULATED.
UPON GOOD CAUSE SHOWN and by stipulation of all parties, it is hereby ordered that this matter be set for further status conference as set forth above.
The Court finds excludable time as set forth above to and including August 8, 2011.
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