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United States of America v. Tony Rosales

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


November 30, 2012

UNITED STATES OF AMERICA, PLAINTIFF,
v.
TONY ROSALES,
DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. William B. Shubb

STIPULATION AND PROPOSED ORDER DATE: December 3, 2012 TIME: 9:30 AM

It is hereby stipulated and agreed to between the United States of America through Jill Thomas, Assistant U.S. Attorney, and defendant Tony Rosales, by and through his attorney, Dan 18

Koukol, that the status conference of December 3, 2012 be vacated and that a status conference 19 be set for January 28, 2013 at 9:30 AM. 20

This continuance is being requested because the parties need time to review the Pre-Plea 21 Probation Report which was completed on November 27, 2012. 22 Counsel agree that the time between the signing of the requested order and January 21, 2013 will be excluded from the speedy trial calculation pursuant to 18 U.S.C. §3161(h)(7)(A) 3 and (B) (Local Code T4) in that the defendants' and the public's interest in a speedy trial are 4 outweighed by the interests of justice in permitting counsel adequate time to prepare. 5 6

DATED: NOVEMBER 29, 2012 Respectfully submitted, 7 /s/ DAN KOUKOL 8 DAN KOUKOL 9 Attorney for defendant Tony Rosales 10 11 DATED: NOVEMBER 29, 2012 Respectfully submitted, 12 /s/ DAN KOUKOL FOR JILL THOMAS 13 _________________________________ JILL THOMAS 14 Assistant U.S. Attorney

IT IS SO ORDERED, that the status conference in the above-entitled matter, scheduled 16 for December 3, 2012, be vacated and the matter continued to January 28, 2013 at 9:30 AM for 17 further status conference. The Court finds that time under the Speedy Trial Act shall be excluded 18 through that date in order to afford counsel reasonable time to prepare. Based on the parties' 19 representations, the Court finds that the ends of justice served by granting a continuance 20 outweigh the best interests of the public and the defendants to a speedy trial. 21

20121130

© 1992-2012 VersusLaw Inc.



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