The opinion of the court was delivered by: Judge: Hon. William B. Shubb
DANIEL J. BRODERICK, Bar #89424 Federal Defender JEFFREY L. STANIELS, Bar #91413 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant IVAN LEYVA
STIPULATION AND [PROPOSED] ORDER
EXCLUDING TIME Date: October 22, 2012
Time: 9:30 a.m.
IT IS STIPULATED by and among Assistant United States Attorney Daniel S. McConkie, Jr., Counsel for Plaintiff, Assistant Federal Defender Jeffrey L. Staniels, Counsel for Defendant Ivan Leyva, and Thomas A. Johnson, counsel for Defendant Alvino Salmeron, that the status conference currently scheduled for October 22, 2012, be vacated and continued until November 19, 2012, for further status conference.
This continuance is sought to permit counsel to continue ongoing conversations regarding a possible plea agreement, to review recently received additional discovery, and to consult with clients who are housed in Nevada County. The court is advised that recent discussions have resulted in substantial progress toward finalizing offers from the government which are expected to be made within the next week or ten days.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act be excluded from October 22, 2012, through and including November 19, 2012, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T-4 (defense preparation and continuity of counsel)
Based on the representations of counsel, the court finds that the interests of justice served by granting additional time as requested by counsel until November 19, 2012,outweigh the best interest of the public and the defendants in a speedy trial.
The request for a continuance is therefore GRANTED, and time for trial under the Speedy Trial Act is excluded pursuant to 18 U.S.C. §3161(h)(7)(B)(iv), Local Code T-4, from October 22, 2012 until November 19, 2012.
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