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United States of America v. Hanrahan

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


October 12, 2012

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HANRAHAN, JORGE SANDOVAL, ET AL., DEFENDANTS.

STIPULATION AND [PROPOSED]

ORDER TO EXCLUDE TIME ROBERT

The parties hereby stipulate that the status conference in this case be continued from Monday, October 15, 2012, at 9:30 a.m. to Monday, November 5, 2012, at 9:30 a.m. The parties stipulate that the time between October 15, 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, counsel for defendant Sandoval will be out of the country on a preplanned, prepaid vacation on the court-proposed date of October 29, 2012. Therefore the parties have stipulated to continue the status conference in this 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)(A).

The parties further request that this matter be taken off the October 15, 2012 calendar before Judge William B. Shubb and be rescheduled for November 5, 2012, at 9:30 a.m. before Judge Shubb.

Respectfully submitted LAW OFFICES OF TIM A. PORI Date: October 12, 2012 /s/ Tim A. Pori TIM A. PORI Attorney for Defendant JORGE SANDOVAL Date: October 12, 2012 /s/ Philip Cozens (Authorized 10/12/12) PHILIP COZENS Attorney for Defendant CAROLYN HUERTA Date: October 12, 2012 /s/ Linda Fullerton (Authorized 10/9/12) LINDA FULLERTON Attorney for Defendant ROBERT HANRAHAN Date: October 12, 2012 /s/ Jason Hitt (Authorized 10/9/12) JASON HITT Assistant United States Attorney Date: October 12, 2012 /s/ William S. Wong (Authorized 10/9/12) WILLIAM S. WONG Assistant United States Attorney

ORDER

IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter is continued to November 5, 2012, at 9:30 a.m. before the Honorable William B. Shubb and that the time between October 15, 2012, and November 5, 2012, be excluded from the calculation of time under the Speedy Trial Act.

20121012

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