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United States of America v. Joe L. Regalado

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


November 21, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JOE L. REGALADO,
DEFENDANT.

STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from November 26, 2012, to January 14, 2013. They stipulate that the time between November 26, 2012, and January 14, 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), Local Code T4. Specifically, the parties are investigating ownership interests in some items that might be subject to forfeiture and the answer to that question is likely to affect the terms of a resolution without trial. In addition, attorney schedules around the upcoming holidays have limited the dates that the parties are able to appear.

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).

Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney DATE: November 21, 2012 /s/ Matthew G. Morris MATTHEW G. MORRIS Assistant U.S. Attorney DATE: November 21, 2012 /s/ Tim Tuitavuki (auth.11/8/12) TIMOTE TUITAVUKI Attorney for Defendant

SO ORDERED.

20121121

© 1992-2012 VersusLaw Inc.



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