Opinion
KYLE R. KNAPP, ATTORNEY AT LAW, Sacramento, CA, Attorney for Defendant JOSE JUNEZ RAMIREZ, SR.
BENJAMIN B. WAGNER, UNITED STATES ATTORNEY, MICHELE BECKWITH, Assistant U.S. Attorney, Attorney for Plaintiff.
AMENDED STIPULATION AND ORDER CONTINUING CASE AND EXCLUDING TIME
MORRISON C. ENGLAND, Jr., Chief District Judge.
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michele Beckwith, Assistant United States Attorney, attorney for plaintiff, together with Kyle Knapp, attorney for defendant JOSE JUNEZ-RAMIREZ-SR., that the previously-scheduled status conference, currently set for September 10, 2015, be vacated and that the matter be set for status conference on September 24, 2015, at 9:00 a.m.
This continuance is requested to allow defense counsel additional time to resolve some legal and investigative issues that are critical in finalizing the plea agreement..
IT IS FURTHER STIPULATED that the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendant in a speedy trial and that time within which the trial of this case must be commenced under the Speedy Trial Act should therefore be excluded under 18 U.S.C. Section 3161(h)(7)(B) (iv), corresponding to Local Code T-4 (to allow defense counsel time to prepare) from the date of the parties' stipulation, September 8, 2015, up to and including September 24, 2015.
IT IS SO STIPULATED.
ORDER
The Stipulation of the parties is hereby accepted and the requested continuance is GRANTED. This matter shall be dropped from this court's September 10, 2015 criminal calendar and re-calendared for status conference on September 24, 2015. Based on the representations of the parties the court finds that the ends of justice served by granting this continuance outweigh the interests of the public and the defendant in a speedy trial. Time is excluded from the time of the filing of this stipulation on September 8, 2015 through and including September 24, 2015.
IT IS SO ORDERED.