The opinion of the court was delivered by: Judge: Honorable Garland E. Burrell, Jr.
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 RICARDO VENEGAS
STIPULATION AND [PROPOSED ORDER] CONTINUING STATUS CONFERENCE
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Ricardo Venegas, John R. Manning, Esq., counsel for defendant Wendell Stewart, Candace A. Fry, Esq., and counsel for defendant Isauro Jauregui Catalan, Edward C. Bell, Esq., that the status conference presently set for September 2, 2011 be continued to September 30, 2011, at 9:00 a.m., thus vacating the presently set status conference. Further, all of the parties, the United States of America and all of the defendants as stated above, hereby 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 time under the Speedy Trial Act should therefore be under meaning of Title 18, United States Code§ 3161(h)(7)(B)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the continuance is requested to allow more time for defense preparation and possible negotiations for resolution) 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 30, 2011.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. WENDALL STEWART, et al., Defendants.
[PROPOSED] ORDER TO ) CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the September 2, 2011 status conference be continued to September 30, 2011 at 9:00 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) (B) (iv) and Local Code T4 from the date of this order to September 30, 2011.