IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
March 15, 2012
UNITED STATES OF AMERICA,
RALPH MICHAEL SMITH,
DANIEL J. BRODERICK, Bar #89424 Federal Defender ERIC V. KERSTEN, Bar #226429 Assistant Federal Defender 2300 Tulare St., Suite 330 Fresno, California 93721-2226 Telephone: (559) 487-5561 Counsel for Defendant RALPH MICHAEL SMITH
STIPULATION TO CONTINUE STATUS
CONFERENCE AND [PROPOSED] ORDER
Date: April 23, 2012
Time: 10:00 a.m.
Judge: Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, BRIAN ENOS, Assistant United States Attorney, and ERIC V. KERSTEN, Assistant Federal Defender, counsel for defendant, Ralph Michael Smith, that the date for status conference may be continued to April 23, 2012, or the soonest date thereafter that is convenient to the court. The date currently set for status conference is March 19, 2012. The requested new date is April 23, 2012, at 10:00 a.m.
The parties are currently engaged in plea negotiations. Additional time is requested for further investigation and negotiations that will likely result in a resolution of the case. It is anticipated that Mr. Smith will either enter a plea agreement or the parties will request a trial date at the next status conference.
The parties agree that the delay resulting from the continuance shall be excluded as necessary for 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 defendants in a speedy trial.
ORDER IT IS SO ORDERED. 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).
IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE
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