Opinion
No. CR-S 12-394 JAM
01-11-2013
UNITED STATES OF AMERICA, Plaintiff, v. ALVARO HERRERA, Defendant.
DINA L. SANTOS Attorney for ALVARO HERRERA JILL THOMAS Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
Attorney at Law
428 J Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 447-0160
Attorney for Defendant
ALVARO HERRERA
STIPULATION AND ORDER VACATING
DATE, CONTINUING CASE, AND
EXCLUDING TIME
Date Feb. 12, 2013
Judge: John A. Mendez
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Jill Thomas, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant Alvaro Herrera that the status conference scheduled for January 15, 2013 be vacated and the matter be continued to this Court's criminal calendar on February 12, 2013, at 9:45 a.m. for further status.
This continuance is requested by the defense in order to permit counsel to conduct investigation, review discovery, and continue in negotiations with the prosecution in attempt to finalize a plea agreement.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), 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 in a speedy trial.
The Court is advised that all counsel have conferred about this request, that they have agreed to the February 12, 2013, date, and that all Ms. Thomas has authorized Ms. Santos to sign this stipulation on her behalf.
IT IS SO STIPULATED.
_____________
DINA L. SANTOS
Attorney for
ALVARO HERRERA
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JILL THOMAS
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
By the Court,
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Hon. John A. Mendez
United States District Court Judge