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United States v. Covarrubias

United States District Court, Ninth Circuit

August 9, 2013

UNITED STATES OF AMERICA, Plaintiff,
v.
DANIEL COVARRUBIAS, et al. Defendants.

William E. Bonham, SB# 55478, Attorney at Law, Sacramento, California, Attorney for: Jaime Rangel, (Mistakenly identified as Jamie).

BENJAMIN B. WAGNER, United States Attorney, WILLIAM E. BONHAM for OLUSERE OLOWOYEYE, Assistant U.S. Attorney. WILLIAM E. BONHAM, Counsel for Defendant, Jamie RANGEL.

BARRY REKOON, Counsel for Defendant, Daniel COVARRUBIA.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

GARLAND E. BURRELL, Jr., District Judge.

The defendants, Jamie Rangel and Daniel Covarrubias, by and through their undersigned counsels, and the United States, through its undersigned counsel, hereby agree and request the status conference currently set for Friday, August 9, 2013 at 9:00 am be vacated and continued until Friday, September 13, 2013 at 9:00 am.

A continuance is necessary to provide counsel with additional time to review newly received discovery, conduct a defense investigation, and to initiate plea and sentencing negotiations.

The parties also stipulate that time should be excluded under the Speedy Trial Act due to the needs of counsel for continued case preparation and ongoing plea and sentencing negotiations. Local Code T4 & 18 U.S.C § 3161 (h)(7)(B)(iv).

I, William E. Bonham, the filing party, have received authorization from Barry Rekoon, counsel for defendant Daniel Covarrubias and AUSA Olowoyeye to sign and submit this stipulation and proposed order on their behalf.

Accordingly, the defense and the United States agree and stipulate that the status conference for defendants Jamie Rangel and Daniel Covarrubias should be continued until Friday, September 13, 2013 at 9:00 am. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and defendant in a Speedy Trial. 18 U.S.C. § 3161(h)(7)(A).

ORDER

IT IS SO ORDERED that the status conference for defendants, Jamie Rangel and Daniel Covarrubias, currently set for Friday, August 9, 2013 at 9:00 am should be vacated and continued to Friday, September 13, 2013 at 9:00 am.

I find that the continuance is necessary due to the needs of counsel for continued case preparation and plea/sentencing negotiations. Accordingly, time is excluded under the Speedy Trial Act, due to needs of counsel for additional case preparation and ongoing plea/sentencing negotiations, from August 9, 2013 up to and including September 13, 2013 pursuant to Local Code T4 and 18 U.S.C. § 3161(h)(7)(B)(iv). I find that the ends of justice served by granting this continuance outweigh the best interest of the public and defendant in a speedy trial. 18 U.S.C. § 3161(h) (7)(A).


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