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United States of America v. Jose Salgado Valladares

October 4, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JOSE SALGADO VALLADARES, AKA "GUERRERO," DEFENDANT.



The opinion of the court was delivered by: Lawrence J. O'neill United States District Judge

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ALEJANDRO URIOSTEGUI-RODRIGUEZ, aka FINDINGS AND ORDER

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 a status conference on Tuesday, October 9, 2012, at 8:30 a.m.

2. By this stipulation, the parties move to continue the status conference date until November 26, 2012, at 8:30 a.m. and to exclude time between October 9, 2012, and November 26, 2012.

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

a. The parties agree and stipulate, and request that the Court find the following: 1

a. The government represents that the discovery associated with the most recent case

includes over 3,320 pages of investigative reports and related material, 50 CDs, and 17 DVDs. This discovery has been either produced directly to counsel and/or made available for inspection and

copying.

b. Defense counsel desires additional time to review discovery, conduct further investigation, and discuss final resolution with his client, who is not readily accessible to defense counsel due to her housing assignment. Plea negotiations have been ongoing.

c. Defense counsel 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 ...


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