Opinion
CR. No. 2:12-cr-00187 WBS
03-15-2013
UNITED STATES OF AMERICA, Plaintiff, v. MANOLO REYES and MARIO ABEL RAYA, Defendants.
JOSEPH SCHLESINGER Acting Federal Defender DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant MANOLO REYES CLEMENTE JIMENEZ Attorney for Defendant MARIO ABEL RAYA BENJAMIN B. WAGNER United States Attorney PAUL HEMESATH Assistant United States Attorney Attorney for Plaintiff
JOSEPH SCHLESINGER, #87692
Acting Federal Defender
DOUGLAS J. BEEVERS, USVI #766
Assistant Federal Defender
Designated Counsel for Service
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
MANOLO REYES
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS CONFERENCE
Date: April 29, 2013
Judge: Hon. William B. Shubb
The parties request that the status conference in this case be continued from March 18, 2013, to April 29, 2013 at 9:30 a.m. They stipulate that the time between March 18, 2013 and April 29, 2013 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. §3161(h)(7)(B)(iv) and Local Code T-4. Specifically, defense counsel needs additional time to investigate the facts of the case, to consult with an expert, and examine the contraband. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4.
Respectfully submitted,
JOSEPH SCHLESINGER
Acting Federal Defender
______________________
DOUGLAS BEEVERS
Assistant Federal Defender
Attorney for Defendant
MANOLO REYES
______________________
CLEMENTE JIMENEZ
Attorney for Defendant
MARIO ABEL RAYA
BENJAMIN B. WAGNER
United States Attorney
______________________
PAUL HEMESATH
Assistant United States Attorney
Attorney for Plaintiff
ORDER
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for March 18, 2013, be continued to April 29, 2013, at 9:30 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the April 29, 2013, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4.
IT IS SO ORDERED.
______________________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE