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United States of America v. Agustin Pena-Contreras

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


June 22, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
AGUSTIN PENA-CONTRERAS, ET.AL. DEFENDANT.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2770

STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from June 22, 2012 to August 3, 2012 at 9:00 a.m.. They stipulate that the time between June 22, 2012 and August 3, 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, plea agreements have been provided to both defendants. Defense counsel need additional time to review and discuss the plea agreements and the provisions contained therein with their clients, confirm the proposed advisory guideline stipulations contained within the plea agreements comport with the discovery already provided and prepare for a possible change of plea hearings at the next court appearance.

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 ORDERED.

20120622

© 1992-2012 VersusLaw Inc.



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