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United States of America v. Miguel Valencia

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


July 20, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MIGUEL VALENCIA, DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.

JOHN R. MANNING (SBN 220874) LAW OFFICE OF JOHN R. MANNING 1111 "H" Street, Suite 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant MIGUEL VALENCIA

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: August 12, 2011

Time: 9:00 a.m.

IT IS HEREBY stipulated between the UNITED STATES OF AMERICA through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with counsel for defendant Miguel Valencia, John R. Manning, Esq., that the status conference presently set for July 22, 2011 be continued to August 12, 2011 at 9:00 a.m., for a change of plea, thus vacating the presently set status conference.

Counsel for both parties agree and stipulate that the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendants in a speedy trial and 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 requested continuance is based upon the need for the defense to review and discuss the proposed plea agreement with the defendant) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the change of plea, August 12, 2011.

IT IS SO STIPULATED.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, v. MIGUEL VALENCIA, Defendant.

CR NO. S-08-00123 GEB

[PROPOSED] ORDER TO CONTINUE ) STATUS CONFERENCE

GOOD CAUSE APPEARING, it is hereby ordered that the July 22, 2011 status conference be continued to August 12, 2011 at 9:00 a.m. for a change of plea. 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 to for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE 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 August 12, 2011.

IT IS SO ORDERED.

20110720

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