Opinion
CASE NO. 2:12-CR-287-MCE
03-08-2013
UNITED STATES OF AMERICA, Plaintiff, v. JESUS GAMBOA-MEZA, Defendant.
BENJAMIN B. WAGNER U.S. Attorney JASON HITT, Assistant U.S. Attorney NICHOLAS F. REYES, ESQ. Attorney for Defendant Jesus Gamboa-Meza
BENJAMIN B. WAGNER
United States Attorney
JASON HITT
Assistant U.S. Attorney
501 I Street, Suite 10-100
Sacramento, California 95814
Telephone: (916) 554-2751
NICHOLAS F. REYES, #102114
Attorney at Law
1107 R Street
Fresno, California 93721
Telephone: (559) 486-4500
Facsimile: (559) 486-4533
Email: reyesf@earthlink.net
Attorney for Defendant
JESUS GAMBOA-MEZA
STIPULATION AND
ORDER
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, JASON HITT, Assistant United States Attorney, together with the defendant, JESUS GAMBOA-MEZA and his counsel NICHOLAS F. REYES, that the hearing currently scheduled for March 7, 2013 be continued to April 11, 2013 at 9:00a.m. for anticipation of entry of plea.
The parties acknowledge that the time under the Speedy Trial Act is being excluded under Title 18, United States Code, Section 3161 (h)(1)(D); Title 18, United States Code 3161 (h)(7)(A) and Local Code T4 based on necessary delay in perfecting and finalizing the negotiated plea agreement between the government and defendant; and, the period of delay is jointly requested based on good cause and agreement to finalize the plea agreement for entry of plea at the next scheduled appearance and such delay is necessary as the ends of justice served taken by such action outweigh the best interests of the public and the defendant in a speedy trial.
Respectfully Submitted,
BENJAMIN B. WAGNER
U.S. Attorney
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JASON HITT, Assistant U.S. Attorney
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NICHOLAS F. REYES, ESQ.
Attorney for Defendant
Jesus Gamboa-Meza
ORDER
IT IS HEREBY ORDERED: That the hearing/appearance currently scheduled for March 7, 2013 be continued to April 11, 2013 at 9:00a.m. for entry of plea.
This court finds that ends of justice as specified by stipulation of counsel, are served by this continuance outweigh the best interest the public and the defendant to a speedy trial, and excludes time under the Speedy Trial Act under 18 U.S.C. 3161 (h)(1)(D); 18 USC 3161 (h)(7)(A) and Local Code T4.
IT IS SO ORDERED.
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MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT JUDGE