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United States of America v. Victor Orlando Munoz

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


October 6, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
VICTOR ORLANDO MUNOZ,
DEFENDANT.

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

DANIEL J. BRODERICK, Bar #89424 Federal Defender DOUGLAS BEEVERS, U.S.V.I. Bar #766 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant VICTOR ORLANDO MUNOZ

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME Date: October 21, 2011 Time: 9:00 a.m. Judge: Hon. Garland E. Burrell, Jr.

IT IS HEREBY STIPULATED by the parties through their respective counsel, Michele Beckwith, Assistant United States Attorney, attorney for Plaintiff, and Douglas Beevers, Assistant Federal Defender, attorney for defendant, VICTOR ORLANDO MUNOZ, that the Status Conference presently scheduled for October 7, 2011 be vacated, and rescheduled for Status Conference on October 21, 2011 at 9:00 a.m.

This continuance is requested to allow the parties additional time to negotiate a fast-track plea toward resolution of the case once the PreSentence Investigative Report has been prepared and reviewed with Mr. Munoz.

To afford time to complete these tasks, the parties agree that the time under the Speedy Trial Act should be excluded from the date of signing of this order through and including October 21, 2011 pursuant to 18 U.S.C. §3161 (h)(7)(A) and (B)(iv) [reasonable time to prepare] and Local Code T4 based upon continuity of counsel and defense preparation. Dated: October 5, 2011 Respectfully submitted,

ORDER IT IS SO ORDERED. For the reasons set forth above, the court specifically finds that the ends of justice served by granting of such a continuance outweigh the best interest of the public and the defendant in a speedy trial and therefore excludes time under the Speedy Trial Act through October 21, 2011.

20111006

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