BENJAMIN B. WAGNER United States Attorney TODD A. PICKLES Assistant United States Attorney Sacramento, CA Attorneys for Plaintiff United States of America
VICTOR SHERMAN, ESQ. Counsel for Defendant Jose Enrique Velardes Zazueta
TIMOTHY WARRINER, ESQ. Counsel for Defendant Francisco Parra Arrellanez
DINA SANTOS, ESQ. Counsel for Defendant Jovany Romo Arrellanes
RICKY POON, ESQ. Counsel for Defendant Yu Nung Chen
RICHARD DUDEK, ESQ. Counsel for Defendant Efrain Padilla Pena
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER
GARLAND E. BURRELL, Jr., District Judge
Plaintiff United States of America, by and through its counsel of record, and defendants Jose Enrique Velardes Zazueta, Francisco Parra Arrellanez, Jovany Romo Arrellanes, Yu Nung Chen, and Efrain Padilla Pena, by and through their counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on January 24, 2014.
2. By this stipulation, defendant now moves to continue the status conference until March 21, 2014 and to exclude time between January 24, 2014 and March 21, 2014 under Local Code T4. The United States does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the discovery associated with this case includes investigative reports produced to defendants numbering approximately 800 pages. All of this discovery has been produced directly to counsel.
b) Further, the United States anticipates making a further production of documents and audio recordings, including intercepted communications, within the next few ...