Opinion
CASE NO. 2:10-cr-00078 MCE
09-28-2011
DINA L. SANTOS Attorney for Defendant FREDDY LOIZA SCOTT CAMERON Attorney for Defendant ISRAEL BALLARDO JILL THOMAS Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
A Professional Law Corporation
Attorney for:
FREDDY LOIZA
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
TIME: 9:00 a.m.
COURT: Hon. Morrison England, Jr.
Stipulation
The parties, through undersigned counsel, stipulate that the status conference, scheduled for September 29, 2011, may be continued to November 10, 2011, at 9:00 a.m.,for further status and possible change of plea.
This continuance is requested by the defense in order to permit further diligent examination of possible defenses, further client consultation concerning available courses of action, review of discovery and further negotiations with the prosecutor in an attempt to reach a final resolution. Plea agreements have been provided to Counsel; however, Mr. Loiza would like to have the plea agreement translated into Spanish in writing so that he can have time to thoroughly review the contents of the agreement.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to §
3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.
The Court is advised that all counsel have conferred about this request, that all have agreed to the November 10, 2011 date, and that all Counsel have authorized Ms. Santos to sign this stipulation on their behalf.
IT IS SO STIPULATED.
DINA L. SANTOS
Attorney for Defendant
FREDDY LOIZA
SCOTT CAMERON
Attorney for Defendant
ISRAEL BALLARDO
JILL THOMAS
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE