IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
November 17, 2011
UNITED STATES OF AMERICA,
JOSE OLIVERA ZAPIEN, ET.AL.
BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2770
STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from November 21, 2011 to January 23, 2012 at 9:30 a.m. They stipulate that the time between November 21, 2011 and January 23, 2012 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv)and Local Code T-4. Specifically, all defense counsel need additional time to review the discovery provided and investigate the case. Well over 2000 pages of discovery and 80 CD's containing video, audio recordings and photographs have been provided to the defense counsel to date. Defense counsel are still reviewing approximately 1200 new pages of discovery provided by the government in January 2011. Further, the parties are actively engaged in plea negotiations and it is anticipated this time period will aide in the resolution of this case for a number of parties. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney
DATE: November 17, 2011
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