October 24, 2013
UNITED STATES OF AMERICA, Plaintiff,
JOSE AGUILAR-MADRIZ, et al., Defendants.
CLEMENTE M. JIMÉNEZ, ESQ., California State Bar Number 207136 Sacramento, CA, Attorney for MOSES PULIDO-AGUILAR
BENJAMIN B. WAGNER, JUSTIN LEE, Attorney for Plaintiff.
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
GARLAND E. BURRELL, Jr., Senior District Judge.
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Justin Lee, Counsel for Plaintiff, and Attorneys Clemente M. Jimenez, Counsel for Defendant MOSES PULIDO-AGUILAR; Michael B. Bigelow, Counsel for Defendant DAVID MARTINELLI; Hayes Gable, Counsel for Defendant GABINO CUEVAS-HERNANDEZ; John R. Manning, Counsel for Defendant RONALD REEVES; Dan F. Koukol, Counsel for Defendant ARTEMIO AGUILAR; and Carl E. Larson, Counsel for Defendant JUAN SILVA; that the status conference scheduled for October 25, 2013, at 9:00 a.m., be vacated and the matter continued to this Court's criminal calendar on January 10, 2013, at 9:00 a.m. for further status conference. Defense counsel require additional time to review discovery, conduct additional investigation, and confer with their respective clients. Furthermore, the parties anticipate forthcoming plea agreements as to the remaining defendants, requiring additional time for counsel to confer with their respective clients.
IT IS FURTHER STIPULATED that time within which the trial of this case must be commenced under the Speedy Trial Act, 18 U.S.C. Section 3161 et seq. be excluded from computation of time pursuant to Section 3161(h)(7)(A) and (B)(iv), (Local code T-4), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant to a speedy trial.
IT IS SO ORDERED, that the status conference in the above-entitled matter, scheduled for October 25, 2013, at 9:00 a.m., be vacated and the matter continued to January 10, 2013, at 9:00 a.m., for further status conference. The Court finds that time under the Speedy Trial Act shall be excluded through that date in order to afford counsel reasonable time to prepare. Based on the parties' representations, the Court finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the defendants to a speedy trial.