Opinion
CASE NO. 2:10-CR-00437-02 WBS
01-24-2013
UNITED STATES OF AMERICA, Plaintiff, v. TONY ROSALES, Defendant.
DAN KOUKOL Attorney at Law Attorney for Defendant, TONY ROSALES
DAN KOUKOL
Attorney at Law
Attorney for Defendant,
TONY ROSALES
STIPULATION AND ORDER
DATE: March 4, 2013
JUDGE: Hon. William B. Shubb
It is hereby stipulated and agreed to between the United States of America through Jill Thomas, Assistant U.S. Attorney, and defendant Tony Rosales, by and through his attorney, Dan Koukol, that the status conference of January 28, 2013 be vacated and that a status conference be set for March 4, 2013 at 9:30 AM.
This continuance is being requested because the defendant recently received a pre-plea probation department sentencing recommendation and is awaiting a written plea offer from the government.
Counsel agree that the time between the signing of the requested order and March 4, 2013 will be excluded from the speedy trial calculation pursuant to 18 U.S.C. §3161(h)(7)(A) and (B) (Local Code T4) in that the defendants' and the public's interest in a speedy trial are outweighed by the interests of justice in permitting counsel adequate time to prepare.
Respectfully submitted,
____________
DAN KOUKOL
Attorney for defendant Tony Rosales
Respectfully submitted,
DAN KOUKOL FOR JILL THOMAS
JILL THOMAS
Assistant U.S. Attorney
IT IS SO ORDERED, that the status conference in the above-entitled matter, scheduled for January 28, 2013, be vacated and the matter continued to March 4, 2013 at 9:30 AM for further status conference. The Court finds that time under the Speedy Trial Act shall be excluded through that date in order to afford counsel reasonable time to prepare. Based on the parties' representations, the Court finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the defendants to a speedy trial.
____________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE