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United States of America v. David Romo

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


October 27, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
DAVID ROMO, DEFENDANT.

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

JOSEPH J. WISEMAN, ESQ., CSBN 107403 WISEMAN LAW GROUP, P.C. 1477 Drew Avenue, Suite 106 Davis, California 95618 Telephone: 530.759.0700 Facsimile: 530.759.0800 Attorney for Defendant DAVID ROMO

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: December 9, 2011 Time: 9:00 a.m.

Ctrm: Garland E. Burrell, Jr.

IT IS HEREBY STIPULATED by the parties, The UNITED STATES OF AMERICA, through undersigned counsel, Russell L. Carlberg, Assistant United States 18 Attorney, and Joseph J. Wiseman, attorney for DAVID ROMO, that the status 19 conference presently set for October 28, 2011 be continued to December 9, 2011 at 9:00 20 a.m.

Specifically, counsel has been informed that the Government will file a 22 Superseding Indictment and will providing an additional seven boxes of discovery for 23 review. The defendant and his counsel need additional time to review the implications 24 of the new charges and discovery.

Therefore, the parties, the United States of America and the defendant, hereby 26 agree and stipulate that the ends of justice served by the granting of such a continuance 27 outweigh the best interests of the public and the defendant in a speedy trial and that time under the Speedy Trial Act should therefore be excluded under 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T-4 (to allow defense counsel time to prepare, review the forensic examination, discuss plea agreement and possible resolution with government, and analyze how best to proceed with the case) from the date of the parties' 4 stipulation, October 28, 2011, to and including December 9, 2011.

IT IS SO STIPULATED.

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

Case No. CR.S. 2:11 0209 GEB

UNITED STATES OF AMERICA, Plaintiff, v. DAVID ROMO Defendant.

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

DAVID ROMO,

Date: December 9, 2011 Time: 9:00 a.m.

Ctrm: Garland E. Burrell, Jr.

GOOD CAUSE APPEARING, it is hereby ordered that the status conference presently set for October 28, 2011 be continued to December 9, 2011 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the 19 defendant's need for a reasonable time for effective preparation exceeds the public 20 interest in a trial within 70 days.

THEREFORE IT IS FURTHER ORDERED that time be 21 excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 from the date of 22 this order to December 9, 2011.

IT IS SO ORDERED.

20111027

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