UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
July 19, 2012
UNITED STATES OF AMERICA,
ERIK F. AGUILAR LARA, DEFENDANT.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties hereby stipulate that the Change of Plea hearing in this case be continued from Monday, July 30, 2012, at 9:30 a.m. to August 13, 2012, at 9:30 a.m. The parties stipulate that the time between July 30, 2012, and August 13, 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, counsel for defendant Lara is going to trial for the second time in a double-homicide case estimated to last one month. Therefore, to ensure continuity of counsel for defendant Lara, the parties have stipulated to continue the Change of Plea hearing in this case. 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).
The parties further request that this matter be taken off the July 30, 2012 calendar before Judge William B. Shubb and be rescheduled for August 13, 2012, at 9:30 a.m. before Judge Shubb.
Respectfully submitted LAW OFFICES OF TIM A. PORI Date: July 24, 2012 /s/ Tim A. Pori TIM A. PORI Attorney for Defendant ERIK LARA Date: July 24, 2012 /s/ Heiko Coppola (Authorized 7/24/2012) HEIKO COPPOLA Assistant United States Attorney
IT IS HEREBY ORDERED that the Change of Plea hearing in the above-entitled matter is continued to August 13, 2012, at 9:30 a.m. before the Honorable William B. Shubb and that the time between July 30, 2012, and August 13, 2012, be excluded from the calculation of time under the Speedy Trial Act.
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