The opinion of the court was delivered by: Judge: Hon. William B. Shubb
STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME
Date: September 19, 2011
Time: 8:30 a.m.
IT IS STIPULATED by and among Assistant United States Attorney Daniel S. McConkie, Jr., Counsel for Plaintiff, Assistant Federal Defender Jeffrey L. Staniels, Counsel for Defendant Ivan Leyva, and Thomas A. Johnson, counsel for Defendant Alvino Salmeron, that the status conference currently scheduled for September 19, 2011, be vacated and continued until November 7, 2011 for further status conference. This continuance is requested to permit further defense preparation and continuity of counsel, and to permit completion of on- going efforts to reach mutually acceptable terms for resolution of the case without trial.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act be excluded from September 19, 2011, through and including November 7, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T-4 (defense preparation and continuity of counsel)
Dated: September 15, 2011 /S/ Daniel S. McConkie DANIEL S. MCCONKIE, JR. Assistant U.S. Attorney Counsel for Plaintiff Dated: September 15, 2011 /S/ Jeffrey L. Staniels JEFFREY L. STANIELS Assistant Federal Defender Attorney for Defendant IVAN LEYVA Dated: September 15, 2011 /S/ Thomas A. Johnson THOMAS A. JOHNSON Attorney for Defendant
Based on the representations of counsel that non-trial discussions are on-going and that further preparation is needed before trial can occur, the court finds that the interests of justice served by granting additional time as requested by counsel until November 7, 2011, outweigh the best interest of the public and the defendants in a speedy trial.
Time for trial under the Speedy Trial Act is therefore excluded pursuant to 18 U.S.C. §3161(h)(7)(B)(iv), Local Code T-4, from September 19, 2011 until November 7, 2011.
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