DINA SANTOS, Attorney for Defendant, SARAVY YEM.
BENJAMIN B. WAGNER, United States Attorney, MATTHEW MORRIS, Assistant United States Attorney, Attorney for Plaintiff.
HEATHER E. WILLIAMS, #122664, Federal Defender, DOUGLAS J. BEEVERS, #288639, Assistant Federal Defender, Designated Counsel for Service, Sacramento, CA, Attorney for Defendant, ANGEL PANTOJA-LOPEZ.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, MATTHEW MORRIS, Assistant United States Attorney, attorney for Plaintiff, DINA SANTOS, attorney for defendant SARAVY YEM, and DOUGLAS BEEVERS, attorney for defendant ANGEL PANTOJA-LOPEZ that the status conference hearing date of October 24, 2013 be vacated, and the matter be set for status conference on December 12, 2013 at 9:30 a.m.
The reason for this continuance is to allow defense counsel additional time to continue to research guideline issues and review discovery, including numerous DVD's which appear to be surveillance videos, discuss the case with the government, pursue investigation, and to negotiate a resolution to this matter.
Based upon the foregoing, the parties agree that the time under the Speedy Trial Act should be excluded from the date of signing of this order through and including December 12, 2013 pursuant to 18 U.S.C. § 3161 (h)(7)(A) and (B)(iv) [reasonable time to prepare] and Local Code T4 based upon continuity of counsel and defense preparation.
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the October 24, 2013, status conference hearing be continued to December 12, 2013, at 9:30 a.m. Based on the representation of defense counsel and good cause appearing there from, the Court hereby finds that 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. The Court 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 up to and including the December 12, 2013 status conference shall be excluded from computation of time within ...