Opinion
NO. 1:11-cr-00017 LJO
01-26-2012
UNITED STATES OF AMERICA, Plaintiff, v. JORGE LUIS CARDEN-REYNA, Defendant.
BENJAMIN B. WAGNER United States Attorney KATHLEEN A. SERVATIUS Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Public Defender MARC DAYS Assistant Federal Defender Attorneys for Defendant Jorge Luis Carden-Reyna
DANIEL J. BRODERICK, #89424
Federal Defender
MARC DAYS, CA Bar #184098
Assistant Federal Defenders
Attorney for Defendant
JORGE LUIS CARDEN-REYNA
STIPULATION TO CONTINUE MOTIONS
SCHEDULE AND HEARING; [PROPOSED]
ORDER
Date: February 27, 2012
Time: 8:30 AM
Judge: Hon. Lawrence J. O'Neill
IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective attorneys of record herein, that the motions hearing now set for February 21, 2012, may be continued to February 27, 2012, at 8:30 A.M., and that a new motions schedule be set as follows:
+-------------------------------------------------------------------------+ ¦Event: ¦Present Date: Requested New Date: ¦ +-------------+-----------------------------------------------------------¦ ¦Motions Due ¦January 27, 2012 February 3, 2012 ¦ +-------------+-----------------------------------------------------------¦ ¦Responses Due¦February 10, 2012 February 17, 2012 ¦ +-------------+-----------------------------------------------------------¦ ¦Hearing ¦February 21, 2012 - 8:30 A.M. February 27, 2012 - 8:30 A.M.¦ +-------------------------------------------------------------------------+
This continuance is requested by counsel for the defendant to allow additional time for investigation and preparation in order to file appropriate motions on behalf of defendant Carden-Reyna. Discovery in this matter is extensive and covers multiple years, states and investigations. There are a number of wiretaps and issues related to the wiretaps that require investigation and analysis in preparing an appropriate motion. The requested continuance will conserve time and resources for both counsel and the court. AUSA Kathleen Servatius has no objection to the requested continuance.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for further defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B), and that the interest ofjustice outweighs the interests of the public and the defendant in a speedy trial
BENJAMIN B. WAGNER
United States Attorney
By: _________________
KATHLEEN A. SERVATIUS
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Public Defender
By: _________________
MARC DAYS
Assistant Federal Defender
Attorneys for Defendant
Jorge Luis Carden-Reyna
ORDER
For the reasons set forth above, the continuance requested is granted for good cause and the Court finds the interest of justice outweighs the interests of the public and the defendant in a speedy trial. IT IS SO ORDERED.
Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE