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United States of America v. Irena Gerez

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


January 14, 2013

UNITED STATES OF AMERICA PLAINTIFF
v.
IRENA GEREZ, DEFENDANT

The opinion of the court was delivered by: Hon John A Mendez United Sates District Court Judge

STIPULATION TO CONTINUE STATUS ORDER

DATE: 3/19/2013 ) Time: 9:45 AM Court: JAM

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on January 15, 2013.

2. By this stipulation, defendant now moves to continue the status conference until March 19, 2013 at 9:45 a.m. and to exclude time between, January 15, 2013, and March 19, 2013 under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery associated with this case includes: investigative reports and related documents in electronic form totaling approximately 1,800 pages. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. On Friday January 10, 2013 Counsel for defendant received a plea agreement from the government and desires additional time to consult with his client, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with his client, to prepare pretrial motions, and to otherwise prepare for trial. Defendant is a Russian speaker and it will take some time to make the necessary arrangements for an interpreter.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.

f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of January 15, 2013 to March 19, 2013, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B (iv) [Local Code T4] (time to prepare), because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period time within which a trial must commence.

/s/Michele Beckwith MICHELE BECKWITH, Esq., Dated: January 14, 2013 Assistant United States Attorney Attorney for Plaintiff /S/MICHAEL B. BIGELOW Dated: January 14, 2013 Michael B. Bigelow Attorney for Defendant Irena Gerez

ORDER

IT IS ORDERED: that pursuant to stipulation the above referenced matter shall be continued until March 19, 2013 at 9:45 AM, and time excluded for the reasons set forth above.

John A. Mendez

20130114

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