The opinion of the court was delivered by: Judge: Honorable Garland E. Burrell, Jr.
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant RICARDO VENEGAS
STIPULATION AND [PROPOSED ORDER] CONTINUING
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Jill M. Thomas, Assistant United States Attorney, together with counsel for defendant Ricardo Venegas, John R. Manning, Esq., that the status conference presently set for June 8, 2012 be continued to July 13, 2012, at 9:00 a.m., thus vacating the presently set status conference.
Further, all of the parties, the United States of America and all of the defendants as stated above, 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 defendants in a speedy trial and that time under the Speedy Trial Act should therefore be under meaning of Title 18, United States Code§ 3161(h)(7)(B)(iv) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, July 13, 2012. The continuance is requested to allow more time for defense preparation and possible negotiations for resolution. Additionally, the United States Probation Department is in the process of preparing a pre-plea report for the purpose of calculating defendant Ricardo Venegas' criminal history; the results of the report will be used to further negotiate a disposition.
GOOD CAUSE APPEARING, it is hereby ordered that the June 8, 2012 status conference be continued to July 13, 2012 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161 (h) (7) (B) (iv) and Local Code T4 from the date of this order to July 13, 2012.
GARLAND E. BURRELL, JR. United States District Judge
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