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United States v. Aguilar-Madriz

United States District Court, Ninth Circuit

June 20, 2013

JOSE AGUILAR-MADRIZ, et al. Defendants.

PRECILIANO MARTINEZ, Attorney for Defendant Jose Aguilar-Madriz.

DAN F. KOUKOL, Attorney for Defendant Artemio Aguilar.

CARL E. LARSON, Attorney for Defendant Juan Silva.

J TONEY Attorney for Defendant Salvador Silva.

MICHAEL B. BIGELOW, Attorney for Defendant David Martinelli.

SCOTT N. CAMERON, Attorney for Defendant Gregorio Zapien-Mendoza.

HAYES H. GABLE, Attorney for Defendant Gabino Cuevas-Hernandez.

CLEMENTE JIMENEZ, Attorney for Defendant Moses Puledo Aguilar.

ERIN J. RADEKIN, Attorney for Defendant Adan Gutierrez Cruz.

KYLE R. KNAPP, Attorney for Defendant Manuel Madriz Sanchez.

OLAF W. HEDBERG, Attorney for Defendant Pedro Aguilar Aguilar.

Benjamin B. Wagner, United States Attorney. Daniel McConkie, Assistant U.S. Attorney. JOHN R. MANNING, (SBN 220874) ATTORNEY AT LAW, Sacramento, CA, Attorney for Defendant RONALD REEVES.


GARLAND E. BURRELL, Jr., Senior District Judge.

The United States of America through its undersigned counsel, Daniel McConkie, Assistant United States Attorney, together with counsel for defendant Jose Aguilar-Madriz, Preciliano Martinez, Esq., counsel for defendant Ronald Reeves, John R. Manning, Esq., counsel for defendant Artemio Aguilar, Dan F. Koukol, Esq., counsel for defendant Juan Silva, Carl E. Larson, Esq., counsel for defendant Salvador Silva, J Toney, Esq., counsel for defendant David Martinelli, Michael B. Bigelow, Esq., counsel for defendant Gregorio Zapien-Mendoza, Scott N. Cameron, Esq., counsel for defendant Gabino Cuevas-Hernandez, Hayes H. Gable, III, Esq., counsel for defendant Moses Puledo Aguilar, Clemente Jimenez, Esq., counsel for defendant Adan Gutierrez Cruz, Erin J. Radekin, Esq., counsel for defendant Manuel Madriz Sanchez, Kyle R. Knapp, Esq., and counsel for defendant Pedro Aguilar Aguilar, Olaf W. Hedberg, Esq., hereby stipulate the following:

1. By previous order, this matter was set for status conference on June 21, 2013.

2. By this stipulation, the defendants now move to continue the status conference until August 2, 2013 and to exclude time between June 21, 2013 and August 2, 2013 under the Local CodeT-4 (to allow defense counsel time to prepare).

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

a. Counsel for the defendants need additional time to review the discovery, conduct investigation, and continue negotiations with prosecution in an effort to reach a resolution.
b. Currently the discovery in this case includes 129 pages and two video DVDs.
c. Counsel for the defendants believe the failure to grant a continuance in this case would deny defense counsel 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 granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial within the original date prescribed by the Speedy Trial Act.
f. For the purpose of computing time under the Speedy Trial Act, 18 United States Code Section 3161(h)(7)(A) within which trial must commence, the time period of June 21, 2013 to August 2, 2013, inclusive, is deemed excludable pursuant to 18 United States Code Section 3161(h)(7)(A) and (B)(ii) and (iv), corresponding to Local Code T-4 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 defendants 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 within which a trial must commence.



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