Opinion
No. 1:12-cr-0322 AWI-BAM
01-18-2013
UNITED STATES OF AMERICA, Plaintiff, v. JOAQUIN OTIS SANTOS, Defendant.
BENJAMIN B. WAGNER United States Attorney LAUREL J. MONTOYA Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender CHARLES J. LEE Assistant Federal Defender Attorneys for Defendant JOAQUIN OTIS SANTOS
JOSEPH SCHLESINGER, Bar #87692
Acting Federal Defender
CHARLES J. LEE, Bar #221057
JANET BATEMAN, Pennsylvania Bar #208063
Assistant Federal Defenders
Designated Counsel for Service
2300 Tulare Street, Suite 330
Fresno, California 93721-2226
Telephone: (559) 487-5561
Attorneys for Defendant
JOAQUIN OTIS SANTOS
STIPULATION AND ORDER TO CONTINUE
STATUS CONFERENCE HEARING
DATE: March 11, 2013
JUDGE: Hon. Barbara A. McAuliffe
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for January 28, 2013, may be continued to March 11, 2013 at 1:00 p.m. before Magistrate Barbara A. McAuliffe.
This continuance is at the request of defense counsel as defense needs additional time in preparation of this case. The government has informed defense they intend to provide an offer on both of Mr. Santos' cases next week. The defense will then need additional time to review the offer with Mr. Santos. Mr. Santos is currently staying at the residential Tulare River Alcoholism Program and is doing well there. Defense counsel plan to go visit Mr. Santos in the near future to review the case and the government's offer with him.
The requested continuance is with the intention of conserving time and resources for both parties and the court. The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation, defense investigation, and plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: _________________
LAUREL J. MONTOYA
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
By: _________________
CHARLES J. LEE
Assistant Federal Defender
Attorneys for Defendant
JOAQUIN OTIS SANTOS
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
IT IS SO ORDERED.
Barbara A. McAuliffe
UNITED STATES MAGISTRATE JUDGE