IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 23, 2012
UNITED STATES OF AMERICA,
THE SPEEDY TRIAL ACT SERGIO ALFONSO AND MARIO ALFONSO MADRIGAL- FELIX, DEFENDANTS.
The opinion of the court was delivered by: Judge: William B. Shubb
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE AND TO EXCLUDE TIME PURSUANT TO DATE: November 19, 2012 TIME: 9:30 a.m.
It is hereby stipulated and agreed to between the United States of America through Christopher Hales, Assistant U.S. Attorney, and defendants, SERGIO ALFONSO MADRIGAL-FELIX by and through his counsel, Clemente Jimenez, and MARIO ALFONSO MADRIGAL-FELIX by and through his counsel, Matthew C. Bockmon, Assistant Federal Defender, that the status conference hearing date of November 5, 2012, be vacated and a new status conference hearing date of Monday, November 19, at 9:30 a.m., be set.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendants, to examine possible defenses, and to continue investigating the facts of the case.
It is further stipulated and agreed between the parties that the time period from October 23, 2012, through and including the date of the new status conference hearing, November 19, 2012, 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 T4 [reasonable time for defense counsel to prepare].
DATED: October 23, 2012 Respectfully submitted, DANIEL J. BRODERICK Federal Defender /s/ Matthew C. Bockmon MATTHEW C. BOCKMON Assistant Federal Defender Attorney for Defendant MARIO ALFONSO MADRIGAL-FELIX DATED: October 23, 2012 /s/ Matthew C. Bockmon for CLEMENTE JIMENEZ Attorney for Defendant SERGIO ALFONSO MADRIGAL-FELIX DATED: October 23, 2012 BENJAMIN B. WAGNER United States Attorney /s/ Matthew C. Bockmon for CHRISTOPHER HALES Assistant U.S. Attorney Attorney for Plaintiff
Based on the reasons set forth in the stipulation of the parties filed on October 23, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDERED that the status conference currently scheduled for Monday, November 5, 2012, be vacated and that the case be set for Monday, November 19, at 9:30 a.m. The Court finds that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that, for the reasons stated in the parties' October 23, 2012, stipulation, the time within which the trial of this matter must be commenced under the Speedy Trial Act is excluded during the time period from the date of this stipulation, October 23, 2012, through and including November 19, 2012, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) and Local Code T4.
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