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United States of America v. Mario Abel Raya

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


January 8, 2013

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MARIO ABEL RAYA,
DEFENDANTS.

JOSEPH SCHLESINGER, #87692 Acting Federal Defender DOUGLAS J. BEEVERS, USVI #766 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant MANOLO REYES

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: March 18, 2013 MANOLO REYES and Time: 9:30 a.m. Judge: Hon. William B. Shubb

The parties request that the status conference in this case be continued from January 14, 2013, to March 18, 2013 at 9:30 a.m. They stipulate that the time between January 14, 2013 and March 18, 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, defense counsel needs additional time to consult with an expert and examine the contraband. 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)(B)(iv) and Local Code T-4.

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for January 14, 2013, be continued to March 18, 2013, at 9:30 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the March 18, 2013, status conference 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 T-4.

IT IS SO ORDERED.

20130108

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