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United States of America v. David Martinelli Jose Aguilar-Madriz Ronald Reeves

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


September 20, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
DAVID MARTINELLI JOSE AGUILAR-MADRIZ RONALD REEVES ARTEMO AGUILAR SALVADOR SILVA JUAN SILVA MOSES AGUILAR GERMAN ALVAREZ ORTEGA ADAN CRUZ MANUEL SANCHEZ PEDRO AGUILAR GABINO CUEVAS-HERNANDEZ GREGPROP ZAPIEN-MENDOZA
DEFENDANTS

CRS 11-365MICHAEL B. BIGELOW Attorney at Law State Bar No. 65211 331 J Street, Suite 200 Sacramento, CA 95814 Telephone: (916) 443-0217 Email:LawOffice.mbigelow@gmail.com Attorney for Defendant David Martinelli

STIPULATION AND ORDER CONTINUING STATUS AND EXCLUDING TIME ORDER (Proposed)

IT IS HEREBY STIPULATED by and between Assistant United States Attorney Dan McConkie, Counsel for Plaintiff, and undersigned counsel for all defendants that the status conference scheduled for September 21, 2012 at 9:00 AM, be vacated and the matter be continued to this Court's criminal calendar on December 14, 2012,at 9:00 a.m. for further status. This continuance is requested by the defense in order to permit counsel time to prepare for the defense of this case and to continue negotiations with the prosecution in an effort to reach resolution.

IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161, et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial. The Court is advised that all counsel have conferred about this request, that they have agreed to the December 14, 2012 date, and that all counsel have authorized Mr. Bigelow to sign this stipulation on their behalf.

IT IS SO STIPULATED

ORDER (Proposed)

IT IS ORDERED: that pursuant to stipulation the above referenced matter shall be continued until December 14, 2012 at 9:00 PM, and time excluded for the reasons set forth above.

20120920

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