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United States of America v. Irena Gerez

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


September 24, 2012

UNITED STATES OF AMERICA PLAINTIFF
v.
IRENA GEREZ, DEFENDANT

The opinion of the court was delivered by: Hon John A Mendez United Sates District Court Judge

STIPULATION TO CONTINUE STATUS AND ORDER DATE: 9/25/12 Time: 9:45 AM Court: JAM

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on September

25, 2012.

2. By this stipulation, defendant now moves to continue the status conference until November 13, 2012 at 9:45 a.m. and to exclude time between, September 25, 2012 and November 13, 2012 under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery associated with this case includes: investigative reports and related documents in electronic form 1,800 pages of documents.

All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. Counsel for defendant desires additional time to consult with his/her client, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with his client, to prepare pretrial motions, and to otherwise prepare for trial.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.

f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of September 25, 2012 to November 13, 2012, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B (iv) [Local Code T4] (time to prepare), because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional

time periods are excludable from the period time within which a trial must commence.

/S/ LEE BICKLEY Lee Bickley, Esq., Dated: September 24, 2012, Assistant United States Attorney Attorney for Plaintiff /S/MICHAEL B. BIGELOW Dated: September 24, 2012 Michael B. Bigelow Attorney for Defendant Irena Gerez

ORDER

IT IS ORDERED: that pursuant to stipulation the above referenced matter shall be continued until November 13, 2012 at 9:40 AM, and time excluded for the reasons set forth above.

20120924

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