Opinion
Case No. 2:11-CR-0298-DAD
09-12-2011
UNITED STATES OF AMERICA, Plaintiff, v. JOCELYN M. AGUSTIN and EMMA Y. MIRADOR, Defendants.
TIM A. PORI Attorney for Defendant MIRADOR LINDA HARTER Attorney for Defendant AGUSTIN DAVID STEVENS Assistant U.S. Attorney
Tim A. Pori (SBN 189270)
John F. Baumgardner (SBN 275674)
LAW OFFICES OF TIM A. PORI
Attorney for Defendant EMMA Y. MIRADOR
AMENDED STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties hereby stipulate that the case management conference in this case be continued from September 13, 2011 to September 20, 2011, at 10:00 a.m. The parties stipulate that the time between September 13, 2011 to September 20, 2011, 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 cannot properly advise his client of the implications of the plea and charges recommended by the Government without additional time to investigate.
Therefore the parties have stipulated to continue the case management conference in this case. 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)(A).
Respectfully submitted
TIM A. PORI
Attorney for Defendant MIRADOR
LINDA HARTER
Attorney for Defendant AGUSTIN
DAVID STEVENS
Assistant U.S. Attorney
[PROPOSED] ORDER
IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter is continued to September 20, at 10:00 a.m. before the Honorable Dale A. Drozd.
_________
MAGISTRATE JUDGE OF THE UNITED
STATES DISTRICT COURT