United States District Court, E.D. California
BENJAMIN B. WAGNER, United States Attorney, TODD A. PICKLES, Assistant United States Attorney, Sacramento, CA Attorneys for Plaintiff United States of America
DANNY BRACE, Counsel for Defendant Emilio Marquez Barba
KATHERINE E. LATHROP, Counsel for Defendant Mario Lopez-Ayala
DUSTIN JOHNSON, Counsel for Defendant Gabriel Vargas-Guerrero
CLEMENTE JIMENEZ, Counsel for Defendant Jose Jaime Diaz
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
CAROLYN K. DELANEY, Magistrate Judge.
1. By previous order, this matter was set for status on March 6, 2014.
2. By this stipulation, defendants now move to continue the status conference until April 10, 2014, at 9:30 a.m., and to exclude time between March 6, 2014, and April 10, 2014, under Local Code T4.
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 approximately 700 pages of documents and photographs, including investigative reports. All of this discovery has been produced directly to counsel.
b) Counsel for defendants desire additional time consult with their clients, conduct investigation and research, review discovery, and to discuss potential resolutions with their clients.
c) Counsel for defendants believe that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into ...