The opinion of the court was delivered by: Honorable Lawrence J. O'Neill
BENJAMIN B. WAGNER United States Attorney JEREMY R. JEHANGIRI Assistant United States Attorney 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: 559-497-4000 Attorneys for Plaintiff United States of America
STIPULATION AND AGREEMENT TO
CONTINUE JURY TRIAL DATE; ORDER
The United States of America, by and through Assistant United States Attorney Jeremy R. Jehangiri, and Defendant Roberto Renteria, Jr., by and through his counsel, Victor Chavez, submit this stipulation for the Court's consideration.
IT IS STIPULATED AND AGREED:
1. The parties request that the jury trial date in this case be continued from June 12, 2012, to October 23, 2012, at 9:00 a.m.
2. The parties stipulate that the time between the date of this Order, and, through and excluding, October 23, 2012, should be excluded from the calculation of time under the Speedy Trial Act.
3. The assigned case agent, who performed most, if not all, of the investigation of this matter, is several months pregnant. The case agent's due date is in late May 2012. The case agent has scheduled maternity leave until August 10, 2012. The undersigned counsel for the United States requests this continuance to maintain continuity of its trial team, to include the assigned case agent, and allow counsel a reasonable amount of additional time to engage in necessary and effective preparation with the assigned case agent, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv).
4. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the United States and 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).
5. 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).
SO STIPULATED AND AGREED.
Granted for good cause, with time excluded for the foregoing legal and factual reasons.
Lawrence J. O'Neill UNITED STATES ...