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United States of America v. Manolo Reyes and Mario Abel Raya

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


March 15, 2013

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

The opinion of the court was delivered by: Judge: Hon. William B. Shubb

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: April 29, 2013 Time: 9:30 a.m.

The parties request that the status conference in this case be continued from March 18, 2013, to April 29, 2013 at 9:30 a.m. They stipulate that the time between March 18, 2013 and April 29, 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 investigate the facts of the case, 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.

Dated: March 15, 2013 Respectfully submitted, JOSEPH SCHLESINGER Acting Federal Defender /s/ Douglas Beevers DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant MANOLO REYES Dated: March 15, 2013 /s/ Clemente Jimenez CLEMENTE JIMENEZ Attorney for Defendant MARIO ABEL RAYA Dated: March 15, 2013 BENJAMIN B. WAGNER United States Attorney /s/ Paul Hemesath PAUL HEMESATH Assistant United States Attorney Attorney for Plaintiff

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for March 18, 2013, be continued to April 29, 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 April 29, 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.

20130315

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