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United States of America v. Francisco Eucebio-Rodriguez

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


March 23, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
FRANCISCO EUCEBIO-RODRIGUEZ
DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: March 30, 2012 Time: 9:00 a.m.

The parties request that the status conference in this case be continued from March 23, 2012, to March 30, 2012 at 9:00 a.m. They stipulate that the time between March 23, 2012 and March 30, 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). Specifically, counsel needs additional time to negotiate a resolution to this matter and to investigate the facts of the case. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(B)(iv).

Dated: March 22, 2012 Respectfully submitted, DANIEL BRODERICK Federal Defender /s/ Douglas Beevers DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant FRANCISCO EUCEBIO-RODRIGUEZ Dated: March 22, 2012 BENJAMIN B. WAGNER United States Attorney /s/ Michele Beckwith Michele Beckwith

Assistant United States Attorney ORDER UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for March 23, 2012, be continued to March 30, 2012, at 9:00 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the March 30, 2012, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4.

GARLAND E. BURRELL, JR. United States District Judge

20120323

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