Tim A. Pori (SBN 189270) John F. Baumgardner (SBN 275674) LAW OFFICES OF TIM A. PORI 521 Georgia Street Vallejo, CA 94590 Telephone: (707) 644-4004 Facsimile: (707) 644-7528 Attorneys for Defendant ERIK F. AGUILAR LARA
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties hereby stipulate that the status conference in this case be continued from Monday, April 9, 2012, at 9:30 a.m. to Tuesday, May 29, 2012, at 9:30 a.m. The parties stipulate that the time between April 9, 2012, and May 29, 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, counsel for defendant Lara is currently in a criminal trial in Contra Costa County that is expected to last through Friday, April 13, 2012, and has a double-homicide trial expected to last six weeks beginning on Monday, April 16, 2012, which cannot be continued. Therefore, to ensure continuity of counsel for Defendant Lara, the parties have stipulated to continue the status conference in this 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)(A).
The parties further request that this matter be taken off the April 9, 2012 calendar before Judge William B. Shubb and be rescheduled for May 29, 2012, at 9:30 a.m. before Judge Shubb.
IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter is continued to May 29, 2012, at 9:30 a.m. before the Honorable William B. Shubb and that the time between April 9, 2012, and May 29, 2012, be excluded from the calculation of time under the Speedy Trial Act.
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