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United States of America v. Mario Abel Raya

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


October 5, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MARIO ABEL RAYA,
DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. William B. Shubb

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: November 5, 2012 MANOLO REYES and Time: 9:30 a.m.

The parties request that the status conference in this case be continued from October 9, 2012, to November 5, 2012 at 9:30 a.m. They stipulate that the time between October 9, 2012 and November 5, 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, defense counsel needs additional time to review the discovery and investigate the facts of the 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)(B)(iv) and Local Code T-4.

Dated: October 4, 2012 Respectfully submitted, DANIEL BRODERICK Federal Defender /s/ Douglas Beevers DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant MANOLO REYES Dated: October 4, 2012 /s/ Clemente Jimenez CLEMENTE JIMENEZ Attorney for Defendant MARIO ABEL RAYA Dated: October 4, 2012 BENJAMIN B. WAGNER United States Attorney /s/ Paul Hemesath PAUL HEMESATH Assistant United States Attorney Attorney for Plaintiff

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for October 9, 2012, be continued to November 5, 2012, at 9:30 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the November 5, 2012, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4.

IT IS SO ORDERED.

20121005

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