The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell,
DANIEL J. BRODERICK, Bar #89424 Federal Defender JEFFREY L. STANIELS, Bar #91413 Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant GAULDRY T. ALMONTE-HERNANDEZ
STIPULATION AND [PROPOSED] ORDER
Date: August 26, 2011
Time: 9:00 a.m.
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Heiko P. Coppola, counsel for Plaintiff, and Assistant Federal Defender Jeffrey Staniels, counsel for defendant GAULDRY T. ALMONTE-HERNANDEZ, that the status conference scheduled for August 26, 2011, be vacated and the matter continued until September 30, 2011, for further status conference at the request of the defense.
The reason for the continuance is to allow completion of further consultation between counsel and Mr. Almonte-Hernandez regarding a proposed plea agreement that has been presented by the government, and presentation to the government of information pertinent to an outstanding sentencing factor ("Safety Valve" eligibility). The date selected also accounts for counsel's schedules and the logistics of conferring with Mr. Almonte-Hernandez who is being held at the Butte County Jail, and who requires the services of an interpreter.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act be excluded between August 26, 2011, and September 30, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(iv), Local Code T-4 (time to prepare).
ORDER The above stipulation of the parties is accepted. The status conference set for August 26, 2011, is VACATED. This case is ordered to be re-calendared on September 30, 2011, for status conference.
The court finds that the interests of justice served by granting this continuance outweigh the interests of the defendant and the public in a speedy trial.
GARLAND E. BURRELL, JR. United States District Judge
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