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United States of America v. Saturnino Vargas-Rivera

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


September 12, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
SATURNINO VARGAS-RIVERA DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.

Date: September 16, 2011 Time: 9:00 a.m.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

The parties request that the status conference in this case be continued from August 26, 2011, to September 16, 2011 at 9:00 a.m. They stipulate that the time between August 26, 2011 and September 16, 2011 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. §3161(h)(7)(B)(iv). Specifically, counsel needs additional time to negotiate a resolution to this matter and to investigate the facts of the case. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(B)(iv).

Dated: August 25, 2011 Respectfully submitted, DANIEL BRODERICK Federal Defender /s/ Douglas Beevers DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant SATURNINO VARGAS-RIVERA Dated: August 25, 2011 BENJAMIN B. WAGNER United States Attorney /s/ Michele Beckwith Michele Beckwith Assistant United States Attorney

ORDER UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for August 26, 2011, be continued to September 16, 2011, at 9:00 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the September 16, 2011, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4.

GARLAND E. BURRELL, JR. United States District Judge

20110912

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