The opinion of the court was delivered by: Judge: Honorable John A. Mendez
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant JOSE MARIA GUTIERREZ
Date: September 27, 2011 Time: 9:30 a.m.
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Heiko P. Coppola, Assistant United States Attorney, together with counsel for defendant Jose Maria Gutierrez, John R. Manning, Esq., that the status conference presently set for August 23, 2011 be continued to September 27, 2011, at 9:30 a.m., thus vacating the presently set status conference.
The requested continuance is based upon the need for defense to review the anticipated plea agreement, discuss it with the defendant, research guidelines applicable to the anticipated plea agreement and prepare the defendant to enter a guilty plea. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (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, September 27, 2011.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARIA GUTIERREZ, Defendant.
ORDER TO CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the August 23, 2011 status conference be continued to September 27, 2011 at 9:30 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.
THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161(h)(7)(A) and Local Code T4 from the date of this order to September 27, 2011.
John A. Mendez United States District ...