IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 12, 2013
UNITED STATES OF AMERICA,
JOE L. REGALADO,
STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from January 14, 2013, to February 4, 2013. They stipulate that the time between January 14, 2013, and February 4, 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 discussing terms of a potential resolution without trial and awaiting records from a previous state prosecution that is relevant to the current charges.
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: January 14, 2013 /s/ Matthew G. Morris MATTHEW G. MORRIS Assistant U.S. Attorney DATE: January 14, 2013 /s/ Tim Tuitavuki (auth.1/11/13) TIMOTE TUITAVUKI Attorney for Defendant
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