JOHN R. MANNING (SBN 220874), ATTORNEY AT LAW, Sacramento, CA, Attorney for Defendant, MANUEL HERRERA.
THOMAS A. JOHNSON, Attorney for Defendant, Moctezuma Tovar.
JOHN R. MANNING, Attorney for Defendant, Manuel Herrera.
BRUCE LOCKE, Attorney for Defendant, Ruben Rodriguez.
RONALD J. PETERS, Attorney for Defendant, Jaime Maorga.
ERIN J. RADEKIN, Attorney for Defendant, Sandra Hermosillo.
MATTHEW M. SCOBLE, Attorney for Defendant, Jun Dirain.
Benjamin B. Wagneer, United States Attorney, LEE BICKLEY, Assistant U.S. Attorney, CHRISTOPHER COSCA, Attorney for Defendant, Christian Renteria.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS
WILLIAM B. SHUBB, District Judge.
The United States of America through its undersigned counsel, Lee Bickley, Assistant United States Attorney, together with counsel for defendant Moctezuma Tovar, Thomas A. Johnson, Esq., counsel for defendant Manuel Herrera, John R. Manning, Esq., counsel for defendant Ruben Rodriguez, Bruce Locke, Esq., counsel for defendant Jaime Mayorga, Ronald J. Peters. Esq., counsel for defendant Sandra Hermosillo, Erin J. Radekin, counsel for defendant Jun Dirain, Matthew M. Scoble, Esq., and counsel for defendant Christian Renteria, Christopher R. Cosca, Esq., hereby stipulate the following:
1. By previous order, this matter was set for status conference on September 9, 2013.
2. By this stipulation, defendants now move to continue the status conference until October 15, 2013 and to exclude time between September 9, 2013 and October 15, 2013 under the Local Code T-4 (to allow defense counsel time to prepare).
3. The parties agree and stipulate, and request the Court find the following:
a. This is voluminous mortgage fraud case involving (allegedly) numerous properties and individuals (including seven co-defendants). Thus far, the Government has produced over 25, 000 pages of discovery (plus numerous audio recordings). The conduct alleged in this matter ...