The opinion of the court was delivered by: Sheila K. Oberto United States Magistrate Judge
Patience Milrod 844 N. Van Ness Avenue Fresno, California 93728 559.442-3111 559.442-3162 fax email@example.com Attorney for CHRISTIAN BARRON-RUEDA
STIPULATION TO CONTINUE STATUS HEARING and ORDER
Date: June 4, 2012 Time: 1:00 p.m. Court: Hon. Sheila Oberto
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, KATHLEEN SERVATIUS, Assistant United States Attorney for Plaintiff, and PATIENCE MILROD, counsel for the Defendant:
1. Defense counsel has received discovery, in the form of 19 DVDs and 4 CDs, with an estimated 1732 pages of written discovery, 222 photographs and 4 videos, each no less than 45 minutes. Three of these DVDs together contain 1931 phone calls, 1 CD contains 107 transcripts, 1 DVD contains 102 documents, and 2 DVDs contain videos totaling an estimated 11 minutes. Currently 2 of these DVDs are not readable and my office is working with Maximus to make them readable.
2. In addition counsel for defendant just received notice, on May 25, 2012, that Maximus studios has additional discovery in the form of 4 DVDs, which will be retrieved today or tomorrow.
3. Counsel for defendant received, on May 29, 2012, this Court's authorization to travel to Kern County Jail (Lerdo) to meet and review discovery with the defendant.
4. Counsel for defendant is in the process of making arrangements to meet with her client at Kern County Jail (Lerdo) either on June 7, 2012 or June 8, 2012 to review the discovery. Depending on how much time the Lerdo officials allow for this meeting, a second meeting may be necessary in order to review completely all pertinent evidence, defenses, and issues related to sentencing.
5. The Government has delivered an offer to resolve the case. Therefore, it is essential that counsel conduct the review of discovery and otherwise confer with her client before the status hearing.
6. In light of all of the above, the parties hereby stipulate to an order continuing the date for the status hearing, from June 4, 2012 at 1:00 p.m. to a new date of July 2, 2012 at 1:00 p.m.
7. The parties further stipulate that time may be excluded through and until July 2, 2012 pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(8)(A), for defense counsel investigation, preparation and filing of motions, and through and until the date of decision on such motions pursuant to 18 U.S.C. §3161(h)(1)(F) and (J).
Having received and reviewed the stipulation of the parties, and good cause appearing therefor,
IT IS HEREBY ORDERED that the status hearing presently set for June 4, 2012 at 1:00 p.m. be and is hereby continued to a new date of July 2, 2012 at 1:00 p.m. Time is excluded through and until July 2, 2012 pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(8)(A), for defense counsel investigation, preparation and filing of motions, and through and ...