Opinion
ERIN J. RADEKIN, Attorney at Law, Sacramento, California, Attorney for Defendant, ANTONIO REYNA.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., Chief District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant Antonia Reyna, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, January 8, 2015 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to February 12, 2015, at 9:00 a.m. in the courtroom of the Honorable Morrison C. England, Jr.
The reason for this request is that the defense and the government need additional time to discuss possible resolution and discovery issues. Also, the defense is still actively engaged in investigation and other defense preparation, and may file a discovery motion. The court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until February 12, 2015, should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of January 8, 2015, at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on February 12, 2015, at 9:00 a.m. The Court finds excludable time in this matter through February 12, 2015 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation.
For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.