Opinion
DINA L. SANTOS, Bar #204200, A Professional Law Corporation, Sacramento, California, Attorney for Defendant, JOSE LUIS MORALES.
KELLY BABINEAU, JUAN MORALES, BRUCE LOCKE, ENRIQUE MORALES, TIMOTHY WARRINER, TERESA MARIA MORALES, DONALD DORFMAN, Attorney for Defendant, PETRA PRECIADO MORALES, KYLE REARDON. Assistant United States Attorney Attorney for Plaintiff.
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
LAWRENCE K. KARLTON, Senior District Judge.
IT IS HEREBY STIPULATED by and between Assistant United States Attorney KYLE REARDON, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant JOSE LUIS MORALES; Attorney Kelly Babineau, Counsel for Defendant JUAN MORALES; Attorney Bruce Locke, Counsel for Defendant ENRIQUE MORALES; Attorney Timothy Warriner, Counsel for Defendant TERESA MARIA MORALES; Attorney Donald Dorfman, Counsel for Defendant PETRA PRECIADO MORALES; that the status conference scheduled for June 25, 2013, be vacated and the matter be continued to this Court's criminal calendar on September 10, 2013, at
This continuance is requested by the defense in order to continue further client consultation concerning available courses of action, review of the thousands of documents that were provided within the last few months, and to continue in negotiations with the Prosecutor to attempt to reach an acceptable disposition.
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 September 10, 2013 date, and that all counsel have authorized Ms. Santos to sign this stipulation on their behalf.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.