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United States of America v. Jorge Sandoval

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


November 2, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JORGE SANDOVAL, DEFENDANT.

STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME

The parties hereby stipulate that the status conference in this case as to defendant Jorge Sandoval only be continued from Monday, November 5, 2012, at 9:30 a.m. to Monday, January 7, 2013, at 9:30 a.m. The parties stipulate that the time between November 5, 2012, and January 7, 2013, 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 must make an appearance in another matter which has only recently been placed on calendar and which cannot be rescheduled. 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 November 5, 2012 calendar before Judge William B. Shubb and be rescheduled for January 7, 2012, at 9:30 a.m. before Judge Shubb.

Respectfully submitted LAW OFFICES OF TIM A. PORI Date: November 2, 2012 /s/ Tim A. Pori TIM A. PORI Attorney for Defendant JORGE SANDOVAL Date: November 2, 2012 /s/ Jason Hitt (Authorized 11/2/12) JASON HITT Assistant United States Attorney Date: November 2, 2012 /s/ William S. Wong (Authorized 11/2/12) WILLIAM S. WONG Assistant United States Attorney

ORDER

IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter as to defendant Jorge Sandoval is continued to January 7, 2013, at 9:30 a.m. before the Honorable William B. Shubb and that the time between November 5, 2012, and January 7, 2013, be excluded from the calculation of time under the Speedy Trial Act.

20121102

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