UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
March 13, 2013
UNITED STATES OF AMERICA, PLAINTIFF,
ALFREDO CONTRERAS, DEFENDANT.
The opinion of the court was delivered by: Honorable Richard Seeborg United States District Court Judge
STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME Date: [HEARING DATE] Time: [HEARING TIME]
On March 12, 2013, at 2:30 p.m., defendant Alfredo Contreras made his
first appearance before
the District Court through counsel. The parties agreed to return
for a status hearing on March 26, 2013 21 at 2:30 p.m. Immediately
prior to the hearing, the government provided Mr. Contreras's attorney
22 additional discovery. The parties agree that Mr. Contreras's
counsel requires time to review the 23 discovery. Therefore, the
parties agreed that time should be excluded between March 12, 2013 and
March 26, 2013 in order to ensure the effective preparation of
counsel. 18 U.S.C. § 3161(h)(7)(B)(iv).
The parties agree that the ends of justice served by granting the continuance outweigh the best interest of 2 the public and the defendant in a speedy trial. 3
DATED: March 12, 2013 Respectfully submitted, 5 MELINDA HAAG United States Attorney 6 7 /s/ FRANK J. RIEBLI 8 Assistant United States Attorney 9 10 DATED: March 12, 2013 /s/ 11 STEVEN KALAR Attorney for ALFREDO CONTRERAS
For the reasons stated above, the Court orders that this matter be continued to 2:30 p.m. on March 26, 2013, in Courtroom 3. The Court finds that the exclusion of time from March 12, 2013 16 through and including March 26, 2013 is warranted and that the ends of justice served by the 17 continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A). The failure to grant the requested continuance would deny the defendant effective 19 preparation of counsel, and would result in a miscarriage of justice. 18 U.S.C. § 3161(h)(7)(B)(iv). 20
DATED: March ____, 2013.
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