IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
September 10, 2012
UNITED STATES OF AMERICA,
GERARDO ARREDONDO DEFENDANT.
The opinion of the court was delivered by: Judge: William B. Shubb
STIPULATION TO CONTINUE
BRIEFING THEREON SCHEDULE; ORDER
Date: October 15, 2012
Time: 9:30 a.m.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, JASON HITT, Assistant United States Attorney, attorney for Plaintiff, and MARK J. REICHEL, Esq., attorney for defendant, that the present dates for the briefing be amended as follows:
Defense filing: September 18, 2012 Government opposition: October 2, 2012 Defense reply: October 9, 2012 Hearing on motions: October 15, 2012 at 9:30 a.m.
This continuance is requested as defense counsel needs adequate time to prepare for the case, and the defense is still reviewing the discovery and researching matters. As well, defense counsel will be in negotiations with the government in an effort to resolve the case.
Accordingly, all counsel and defendant agree that time under the Speedy Trial Act from the date this stipulation is lodged, through October 15, 2012 should be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to Title 18 U.S.C. § 3161 (H)(7)(B)(iv) and Local Code T4.
DATED: September 11, 2012 Respectfully submitted, MARK J. REICHEL, ESQ. /s/ MARK J. REICHEL MARK J. REICHEL Attorney for defendant BENJAMIN WAGNER United States Attorney DATED: September 11, 2012. /s/MARK J. REICHEL for: JASON HITT Assistant U.S. Attorney Attorney for Plaintiff
IT IS SO ORDERED. For the reasons set forth above, the court finds that there is GOOD CAUSE for the continuance and the exclusion of time, and that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial. Time is excluded pursuant to 18 U.S.C. Section 3161(h)(7)(B)(iv) and Local Code T4. Motions hearing is set for October 15, 2012 at 9:30 a.m.
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