The opinion of the court was delivered by: Judge: Hon. Lawrence J. O'Neill
DANIEL J. BRODERICK, Bar #89424 Federal Defender RACHEL W. HILL, Bar #151522 Assistant Federal Defender Designated Counsel for Service 2300 Tulare Street, Suite 330 Fresno, California 93721-2226 Telephone: (559) 487-5561 Attorney for Defendant MIGUEL ANGEL ZARCO
STIPULATION TO CONTINUE STATUS
Date October 21, 2011 Time: 8:30 a.m.
IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective attorneys of record herein, that the Status Conference Hearing in the above-captioned matter scheduled for September 23, 2011, may be continued to October 21, 2011, at 8:30 a.m.
The continuance is requested due to the unavailability of defense counsel, Defendant's housing in a remote facility (Bakersfield), and continued defense preparation and plea negotiations. The unavailability of defense counsel is based upon defense counsel being assigned this matter, with the first status conference already scheduled for September 23rd, notwithstanding that defense counsel had been previously scheduled to be out of state from September 20th through October 7th. With respect to the remote location of defendant, upon defense counsel's return, as October 10th is a holiday, the first available transport from Lerdo for the purpose of attorney/client discussions will be on Friday, October 14th. The first Friday thereafter is the date for the requested continuance, October 21st. The requested continuance will conserve time and resources for both counsel and the court.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for further defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B).
GOOD CAUSE HAS NOW BEEN ESTABLISHED. TIME IS EXCLUDED FOR THE REASONS STATED IN THE STIPULATION.
Lawrence J. O'Neill UNITED STATES DISTRICT JUDGE
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