IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
June 8, 2012
UNITED STATES OF AMERICA,
BENJAMIN B. WAGNER United States Attorney KIMBERLY A. SANCHEZ Assistant U.S. Attorney 2500 Tulare Street, Suite 4401 Fresno, CA 93721 Telephone: (559)497-4000
STIPULATION AND ORDER FOR EXTENSION OF TIME TO
FILE RESPONSE SET A DATE FOR A REPLY AND CONTINUANCE OF
STATUS CONFERENCE AND MOTIONS
IT IS HEREBY STIPULATED by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and Jeremy Kroger, attorney for Jaime Vega, that the time for the government to file its response to the defendant's motion to suppress currently due June 8, 2012 be extended to June 22, 2012; that a date for the defendant's reply to the government's response be set for June 29, 2012; and that the hearing on the motion and status conference currently set for June 18, 2012 be continued to July 2, 2012 at 1:30 p.m. The parties are involved in plea negotiations that have the potential of causing the defendant to withdraw his motion to suppress. The parties agree that they need additional time to do additional background investigation and finalize plea negotiations.
The parties further agree that time will be excluded through the Court's ruling on the motions. Moreover, the parties further request the Court to enter an Order finding that the "ends of justice" served by a continuance outweigh the interest of the public and the defendant in a speedy trial, and that the delay occasioned by such continuance is excluded from the Act's time limits pursuant to 18 U.S.C. § 3161(h)(7)(A).
IT IS SO ORDERED.
CHIEF UNITED STATES DISTRICT JUDGE
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