Opinion
CASE NO. 2:09 MJ 250 DAD
02-21-2013
UNITED STATES OF AMERICA, Plaintiff, v. Sanae Quiroz-Jones, Defendant.
John R. Manning Attorney at Law Attorney for Defendant Sanae Quiroz-Jones
John R. Manning
Attorney at Law
Attorney for Defendant
Sanae Quiroz-Jones
STIPULATION AND ORDER
CONTINUING PRELIMINARY HEARING
The parties to this action, defendant, Sanae Quiroz-Jones and plaintiff, United States of America, hereby stipulate through their respective attorneys to continue the preliminary hearing scheduled for February 21, 2013, at 2:00 p.m to March 14, 2013 at 2:00 p.m.
Ms. Quiroz-Jones' health issues are well know to the Court. The attorneys for both sides have worked to achieve a negotiated resolution in this matter. Thus far, resolution has remained elusive, though the Parties are continuing to confer. To that end, the Parties are meeting on March 14, 2013. The Parties request this matter be set for the March 14, 2013, at 2:00 to allow for further negotiations between the Parties and to allow Counsel for Ms. Quiroz-Jones necessary time to adequately discuss and review the case status; options and future proceedings with Ms. Jones.
The parties agree the above reason constitutes good cause to extend the time for preliminary hearing under Federal Rule of Criminal Procedure 5.1, and that the time within which the indictment must be filed should be extended to March 14, 2013, pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A) and (B)(iv), for the reasons stated above.
Respectfully submitted,
____________
JOHN R. MANNING
Attorney for Defendant
Sanae Quiroz-Jones
Benjamin B. Wagner
United States Attorney
by: __________
TODD D. LERAS
Assistant U.S. Attorney
John R. Manning
Attorney at Law
Ca. St. Bar No. 220874
1111 H Street, Suite 204
Sacramento, CA 95814
Telephone: (916) 444-3994
Attorney for Defendant
Sanae Quiroz-Jones
UNITED STATES OF AMERICA, Plaintiff,
v. Sanae Quiroz-Jones, Defendant.
Case No. 2:09 MJ 250 DAD
ORDER TO
CONTINUE PRELIMINARY HEARING
GOOD CAUSE APPEARING, it is hereby ordered that the February 21, 2013 preliminary hearing for defendant Quiroz-Jones, be continued to March 14, 2013 at 2:00 p.m. I find that the ends of justice warrant an exclusion of time and outweigh the interest of the public and defendant in a speedy trial based on the grounds stated in the stipulation of the parties. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) from the date of this order to March 14, 2013. IT IS SO ORDERED.
____________
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE