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United States of America v. Evodio Zamora-Rodriguez

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


February 6, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
EVODIO ZAMORA-RODRIGUEZ,
DEFENDANT.

The opinion of the court was delivered by: Lawrence J. O'Neill United States District Judge

STIPULATION TO CONTINUE STATUS CONFERENCE AND ORDER THEREON Date: February 21, 2012 Time: 8:30a.m. Judge: Hon. Lawrence J' O'Neill

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, IAN GARRIQUES, Assistant United States Attorney, counsel for plaintiff, and ERIC KERSTEN, Assistant Federal Defender, counsel for defendant Evodio Zamora-Rodriguez, that the date for status conference in this matter may be continued to February 21, 2012, or the soonest date thereafter that is convenient to the court. The date currently set for status conference is February 13, 2012. The requested new date is February 21, 2012.

The government has extended a "fast track" plea offer in this matter and it is anticipated that Mr. Zamora-Rodriguez will accept the offer. However, Zamora-Rodriguez is housed in the Kern County Lerdo detention facility and no space is available on the bus prior to the currently scheduled status conference date of February 13, 2012. A short, one week continuance is requested to allow time for counsel and an interpreter to review the plea offer with Zamora-Rodriguez, in Fresno, prior to the status conference.

The parties agree that the delay resulting from the continuance shall be excluded as necessary for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). For this reason, the ends of justice served by the granting of the requested continuance outweigh the interests of the public and the defendant in a speedy trial.

BENJAMIN B. WAGNER United States Attorney DATED: February 6, 2012 By /s/ Ian Garriques IAN GARRIQUES Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender DATED: February 6, 2012 By /s/ Eric V. Kersten ERIC V. KERSTEN Assistant Federal Defender Attorney for Defendant EVODIO ZAMORA-RODRIGUEZ

ORDER

The intervening period of delay is excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). The requested continuance is granted, having good cause therefor.

IT IS SO ORDERED.

20120206

© 1992-2012 VersusLaw Inc.



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