Opinion
No. CR-S-11-134 JAM
09-16-2011
UNITED STATES OF AMERICA, Plaintiff, v. JUAN LOPEZ ALVARADO, et al., Defendants.
DANNY D. BRACE, JR. Attorney for Defendant Estanislao Garcia MICHAEL L. CHASTAINE Attorney for Defendant Edward Michael Tulysewski JOHNNY L. GRIFFIN, III Attorney for Defendant Michael Caspillo JOHN R. MANNING Attorney for Defendant Fred Pineda MATTHEW MCCRARY SCOBLE Attorney for Defendant Jose Mario Medrano Benjamin B. Wagner United States Attorney MICHAEL M. BECKWITH Assistant U.S. Attorney JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW Attorney for Defendant FRED PINEDA
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
Attorney for Defendant
FRED PINEDA
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
Date: November 1, 2011
Time: 9:30 a.m.
Judge: Honorable John A. Mendez
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michael M. Beckwith, Assistant United States Attorney, together with counsel for defendant Estanislao Garcia, Danny D. Brace, Jr., Esq., counsel for defendant Edward Michael Tulysewski, Michael L. Chastaine, Esq., counsel for defendant Michael Caspillo, Johnny L. Griffin, III, counsel for defendant Fred Pineda, John R. Manning, Esq., and counsel for defendant Jose Mario Medrano, Matthew McCrary Scoble, Esq., that the status conference presently set for September 20, 2011 be continued to November 1, 2011, at 9:30 a.m., thus vacating the presently set status conference.
Further, all of the parties, the United States of America and all of the defendants as stated above, hereby agree and stipulate that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial and that time under the Speedy Trial Act should be excluded under Title 18, United States Code Section 3161(h)(7)(A) and (B)(ii) and (iv), corresponding to Local Codes T-2 (unusual or complex case) and T-4 (to allow defense counsel time to prepare) from the date of the parties' stipulation, September 15, 2011, to and including November 1, 2011. This is based on the complexity of the case, including over 5,000 pages of discovery as well as three discs of recorded phone calls, and the fact there are five co-defendants (a total of 13 Indicted). The defense requests more time to review the discovery and conduct investigation.
IT IS SO STIPULATED.
DANNY D. BRACE, JR.
Attorney for Defendant
Estanislao Garcia
MICHAEL L. CHASTAINE
Attorney for Defendant
Edward Michael Tulysewski
JOHNNY L. GRIFFIN, III
Attorney for Defendant
Michael Caspillo
JOHN R. MANNING
Attorney for Defendant
Fred Pineda
MATTHEW MCCRARY SCOBLE
Attorney for Defendant
Jose Mario Medrano
Benjamin B. Wagner
United States Attorney
MICHAEL M. BECKWITH
Assistant U.S. Attorney
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
Attorney for Defendant
FRED PINEDA
UNITED STATES OF AMERICA, Plaintiff,
v.
JUAN LOPEZ ALVARADO, et al., Defendants.
No. CR-S-11-134 JAM
ORDER TO CONTINUE STATUS CONFERNCE
GOOD CAUSE APPEARING, it is hereby ordered that the September 20, 2011 status conference be continued to November 1, 2011 at 9:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(ii) and (iv) and Local Codes T2 (unusual and complex case) and T4 (preparation by defense counsel).
IT IS SO ORDERED.
John A. Mendez
United States District Court Judge