Opinion
Case No. 12-128 WBS
07-19-2012
UNITED STATES OF AMERICA, Plaintiff, v. GERARDO ARREDONDO Defendant.
MARK J. REICHEL Attorney for defendant BENJAMIN WAGNER United States Attorney JASON HITT Assistant U.S. Attorney Attorney for Plaintiff
MARK J. REICHEL, State Bar #155034
THE LAW OFFICES OF MARK J. REICHEL
Attorney for Defendant
GERARDO ARREDONDO
STIPULATION TO CONTINUE
STATUS CONFERENCE; ORDER
THEREON
Date: August 6, 2012
Judge: WILLIAM B. SHUBB
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, JASON HITT, Assistant United States Attorney, attorney for Plaintiff, and MARK J. REICHEL, Esq., attorney for defendant, that the present dates for the status hearing be re calendared for August 6, 2012.
This continuance is requested as defense counsel needs adequate time to prepare for the case, and the defense is still reviewing the discovery and will be researching matters. As well, defense counsel will be in negotiations with the government in an effort to resolve the case. As well, defense counsel was actually very ill, was hospitalized on July 9 and 10, and is under doctor's orders to not be at work at all for a 2 week period, until July 23, 22012, based on a serious illness.
Accordingly, all counsel and defendant agree that time under the Speedy Trial Act from the date this stipulation is lodged, through August 6, 2012 should be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to Title 18 U.S.C. § 3161 (H)(7)(B)(iv) and Local Code T4.
Respectfully submitted,
MARK J. REICHEL, ESQ.
________________
MARK J. REICHEL
Attorney for defendant
BENJAMIN WAGNER
United States Attorney
MARK J. REICHEL for:
JASON HITT
Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED. For the reasons set forth above, the court finds that there is GOOD CAUSE for the continuance and the exclusion of time, and that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial. Time is excluded pursuant to 18 U.S.C. Section 3161(h)(7)(B)(iv) and Local Code T4. The status conference is reset for August 6, 2012 at 9:30 a.m.
____________________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE