JOHN R. MANNING (SBN 220874), ATTORNEY AT LAW, Sacramento, CA, Attorney for Defendant, ANGEL MARTINEZ-DIAZ.
CHRISTOPHER R. COSCA, Attorney for Defendant,
Jose Maria Villareal, Attorney for Defendant,
VICTOR D. VERTNER, Attorney for Defendant, Jose Ramirez-Verduzco.
Benjamin B. Wagner, United States Attorney,
RICHARD J. BENDER, Assistant U.S. Attorney.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
JOHN A. MENDEZ, District Judge.
The United States of America through its undersigned counsel, Richard J. Bender, Assistant United States Attorney, together with counsel for defendant Jose Maria Villareal, Christopher R. Cosca, Esq., counsel for defendant Angel Martinez-Diaz, John R. Manning, Esq., and counsel for defendant Jose Ramirez-Verduzco, Victor D. Vertner, Esq., hereby stipulate the following (defendant Jose Martinez-Chairez will remain on the November 12, 2013 calendar for change of plea):
1. By previous order, this matter was set for status conference on November 12, 2013. Additionally, by previous order, the following motion schedule was agreed upon: defense motions due 11/26/13; oppositions due 12/10/13; replies due 12/17; and, a hearing on the motions is scheduled for 1/7/14. This previously agreed upon schedule is in no way impacted by this stipulation.
2. By this stipulation, defendants now move to continue the status conference (and anticipated change of plea by one or more or the remaining defendants) until December 10, 2013 and to exclude time between November 12, 2013 and December 10, 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 case currently contains over a 100 pages of discovery as well as two DVD's with videos and one CD of audio recordings (the recordings are in Spanish).
b. Counsel for the defendants need additional time to review the discovery, conduct investigation, and interview potential witnesses.
c. Counsel for defendants believe the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking ...