The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
BENJAMIN B. WAGNER United States Attorney TODD D. LERAS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2918
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY STIPULATED by and between Plaintiff United States of America, by and through United States Attorney Benjamin B. Wagner and Assistant U.S. Attorney Todd D. Leras, and Attorney Michael D. Long, Counsel for Defendant Jose Sanchez-Palomino, that the status conference scheduled for September 6, 2011 be continued to October 6, 2011, at 9:00 a.m.
The request to continue the status conference is made on the ground that the government has provided defense counsel with a proposed Plea Agreement. Defense counsel needs time to review the Plea Agreement with defendant, who requires the services of a Spanish language interpreter. The parties may need additional meetings and consultation in furtherance of efforts to resolve the case. On that basis, the government and defendant agree that an exclusion of time is appropriate under 18 U.S.C. (h)(7)(B)(iv) (reasonable time for counsel to prepare) and Local Code T4 (reasonable time to prepare). This exclusion of time includes the period up to and including October 6, 2011.
Michael Long agrees to this request and has authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on his behalf.
1. The status conference set for September 6, 2011 is continued to October 6, 2011, at 9:00 a.m.
2. Based on the stipulations and representations of the parties, the Court finds that the ends of justice outweigh the best interest of the public and defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Codes T4 (reasonable time to prepare) from September 6, 2011 up to and including October 6, 2011.
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