IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 22, 2012
UNITED STATES OF AMERICA,
STIPULATION AND ORDER FOR EXTENSION OF TIME TO
FILE RESPONSE SET A DATE FOR A REPLY AND CONTINUANCE OF STATUS
CONFERENCE AND MOTIONS
IT IS HEREBY STIPULATED by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and David Balakian, attorney for Salvador Valencia-Galvan, that the time for the government to file its response to the defendant's motion to suppress currently due December 21, 2012 be extended to January 4, 2013; that a date for the defendant's reply to the government's response be set for January 10, 2013; and that the hearing on the motion and status conference currently set for January 7, 2013 be continued to January 14, 2013 at 1:30 p.m. The government needs additional time to complete its response to the defendant's motion. The government had several unanticipated delays due to family and personal illness, and work obligations that took longer than expected. The parties further agree that time will be excluded through the Court's ruling on the motions. Moreover, the parties further request the Court to enter an Order finding that the "ends of justice" served by a continuance outweigh the interest of the public and the defendant in a speedy trial, and that the delay occasioned by such continuance is excluded from the Act's time limits pursuant to 18 U.S.C. § 3161(h)(7)(A).
Dated: December 21, 2012 Respectfully submitted,
BENJAMIN B. WAGNER United States Attorney By /s/ Kimberly A. Sanchez KIMBERLY A. SANCHEZ Assistant U.S. Attorney Dated: December 21, 2012 /s/ David Balakian DAVID BALAKIAN Attorney for the Defendant
IT IS SO ORDERED.
UNITED STATES DISTRICT JUDGE
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