STIPULATION AND [PROPOSED] ORDER CONTINUING PRELIMINARY
IT IS HEREBY STIPULATED between Plaintiff United States of America, by and through Assistant United States Attorney Todd D. Leras, and Danny D. Brace, Counsel for Defendant Juvany Herrera-Felix, that the preliminary hearing scheduled for October 15, 2012, be continued to December 3, 2012, at 2:00 p.m.
The parties have been working toward a pre-indictment resolution of this matter and continue to conduct investigation related to that process. In light of continuing investigation being conducted relevant to the potential disposition, both parties are requesting additional time for attorney preparation.
The government and defendant agree that the combination of settlement discussions and continuing investigation constitute good cause to extend the time for preliminary hearing under Federal Rule of Criminal Procedure 5.1(d), as well as under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(iv). This exclusion of time includes the period up to and including December 3, 2012.
Danny Brace agrees to this request and has authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on his behalf.
DATED: October 12, 2012 By: /s/ Todd D. Leras TODD D. LERAS Assistant U.S. Attorney DATED: October 12, 2012 By: /s/ Todd D. Leras for DANNY D. BRACE, JR. Attorney for Defendant JUVANY HERRERA-FELIX
1. The preliminary hearing set for October 15, 2012, is continued to December 3, 2012, at 2:00 p.m.
2. Based on the stipulations and representations of the parties, the Court finds good cause to extend the time for the preliminary hearing, and time is excluded up to and including December 3, 2012. (18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare)).
© 1992-2012 VersusLaw ...