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United States of America v. Moctezuma Tovar

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


July 26, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MOCTEZUMA TOVAR, MANUEL HERRERA, RUBEN RODRIGUEZ, JAIME MAYORGA, SANDRA HERMOSILLO, JUN MICHAEL DIRAIN, AND CHRISTIAN PARADA RENTERIA
DEFENDANTS.

BENJAMIN B. WAGNER United States Attorney DOMINIQUE N. THOMAS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2891

STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from August 8, 2011 to August 15, 2011 at 8:30 a.m.

They stipulate that the time between August 8, 2011 and August 15, 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). Specifically, defense counsel requires time to review the extensive discovery in this 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).

IT IS SO ORDERED.

20110726

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