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United States of America v. Jose Maria Gutierrez

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


September 22, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JOSE MARIA GUTIERREZ, DEFENDANT.

The opinion of the court was delivered by: John A. Mendez United States District Court Judge

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 JOSE MARIA GUTIERREZ

STIPULATION AND [PROPOSED ORDER] CONTINUING STATUS CONFERENCE

Date: November 1, 2011 Time: 9:30 a.m. Judge: Honorable John A. Mendez

presently set status conference. The requested continuance is based upon the need for defense to review the anticipated plea agreement, discuss it with the defendant, research guidelines applicable to the anticipated plea agreement and prepare the defendant to enter a guilty plea. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) 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, November 1, 2011.

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Heiko P. Coppola, Assistant United States Attorney, together with counsel for defendant Jose Maria Gutierrez, John R. Manning, Esq., that the status conference presently set for September 27, 2011 be continued to November 1, 2011, at 9:30 a.m., thus vacating the

IT IS SO STIPULATED.

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

UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARIA GUTIERREZ, Defendant.

No. CR-S-10-0371 JAM

ORDER TO CONTINUE STATUS CONFERENCE

GOOD CAUSE APPEARING, it is hereby ordered that the September 27, 2011 status conference be continued to November 1, 2011 at 9:30 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)(A) and Local Code T4 from the date of this order to November 1, 2011.

IT IS SO ORDERED.

John A. Mendez

20110922

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