The opinion of the court was delivered by: Garland E. Burrell, Jr.
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 6 7
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE
Date: March 9, 2012 Time: 9:00 a.m. Ctrm:
IT IS HEREBY STIPULATED by the parties, The UNITED STATES OF AMERICA, through undersigned counsel, Russell L. Carlberg, Assistant United States Attorney, and Joseph J. Wiseman, attorney for defendant DAVID ROMO, that the status conference presently set for February 24, 2012, be continued to March 9, 2012, at 9:00 a.m.
This stipulation is being entered into because the government has filed a 22 Superseding Indictment in this case and will provide to the defense additional discovery 23 related to the additional charges filed in this case. The defendant and his counsel need 24 additional time to consider and discuss the impact of the Superseding Indictment and 25 review the additional discovery that the government intends to disclose.
Therefore, the UNITED STATES OF AMERICA and defendant DAVID ROMO, hereby agree and stipulate that the ends of justice served by the granting of such a continuance 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 review the forthcoming discovery and superseding indictment and determine how to best to proceed with the case) from the date of the parties' stipulation, February 24, 2012, to and including March 9, 2012.
PROPOSED ORDER GOOD CAUSE APPEARING, it is hereby ordered that the status conference 23 presently set for February 24, 2012, be continued to March 9, 2012 at 9:00 a.m.
Based on the reasons set forth the Stipulation entered into by the parties, the 25 Court finds that the ends of justice served by the granting of such a continuance 26 outweigh the best interest of the public and the defendant in a speedy trial and warrant 27 an exclusion of time.
THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T4 from the date of this order to March 9, 2012.
GARLAND E. BURRELL, JR. United States District Judge
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