Opinion
No. 2:10-CR-524 JAM
01-20-2012
UNITED STATES OF AMERICA, Plaintiff, v. PEDRO BARAJAS-RODRIGUEZ, Defendant.
Respectfully submitted, BENJAMIN B. WAGNER United States Attorney MICHELE BECKWITH Assistant U.S. Attorney DANIEL J. BRODERICK Federal Defender TIMOTHY ZINDEL Assistant Federal Defender Attorney for Mr. Barajas-Rodriguez
DANIEL J. BRODERICK, Bar #89424
Federal Defender
TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
Sacramento, California 95814
Attorney for Defendant
PEDRO BARAJAS-RODRIGUEZ
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE
AND EXCLUDE TIME
Date: January 24, 2012
Time: 9:30 a.m.
Judge: Hon. John A. Mendez
IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendant, Pedro Barajas-Rodriguez, that the status conference scheduled for January 24, 2012, may be continued one week and the matter set for change of plea and sentencing on January 31, 2012, at 9:30 a.m.
The parties have reached a plea agreement under the government's fast-track program for immigration offenses, but counsel for the government will be in trial on January 24 and thus unavailable. To assure continuity of counsel, the parties ask the Court to find that the interests of justice to be advanced by a one-week continuance outweigh the best interests of the public and the defendant in a speedy trial, and to exclude time under the Speedy Trial Act from the date of this order through the hearing on change of plea to be held January 31, 2012, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
_________________
MICHELE BECKWITH
Assistant U.S. Attorney
DANIEL J. BRODERICK
Federal Defender
_________________
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for Mr. Barajas-Rodriguez
ORDER
The status conference is continued to January 31, 2012, at 9:30 a.m., and the matter shall be calendared for change of plea and sentencing. Time under the Speedy Trial Act is excluded through that date for the reasons stated above, the Court finding that the ends of justice to be served by a continuance outweigh the best interests of the defendant and the public in a speedy trial.
IT IS SO ORDERED.
_________________
HON. JOHN A. MENDEZ
United States District Judge