IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 11, 2011
UNITED STATES OF AMERICA,
JOSE GUTIERREZ-VALENZUELA, DEFENDANT.
The opinion of the court was delivered by: Lawrence J. O'Neill United States District Judge
DANIEL J. BRODERICK, #89424 Federal Defender MARC DAYS, CA Bar #184098 Assistant Federal Defender Designated Counsel for Service 2300 Tulare Street, Suite 330 Fresno, California 93721-2226 Telephone: (559) 487-5561 Attorney for Defendant Jose Gutierrez-Valenzuela
STIPULATION TO CONTINUE MOTIONS SCHEDULE AND HEARING; ORDER Date: November 14, 2011 Time: 1:00 P.M. Judge: Hon. Lawrence J. O'Neill
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the defense shall file it's reply to the government's response to defendant's motion to dismiss on or before November 10, 2011, at 10:00 A.M., and the hearing on motions now set for October 14, 2011, may be continued to November 14, 2011 at 1:00 P.M.
This continuance is requested by counsel for defendant. Counsel is expecting the arrival of a new member of his family on October 14, 2011, and will not be available for court at the time now set. Counsel is scheduled for a period of paternity leave commencing October 14, 2011. Assistant United States Attorney Ian Garriques has no objection to this requested continuance. The requested continuance will provide for continuity of counsel, and will conserve time and resources for both counsel and the court and also allow for continuity of counsel in these proceedings.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for further defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B).
ORDER Granted. There is no question but that GOOD CAUSE has been stated in the stipulation. Time is excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B).
IT IS SO ORDERED.
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