Opinion
No. 3:11-cr-00194-RS-1
10-03-2011
UNITED STATES OF AMERICA Plaintiff, v. GERARDO CASTILLO, Defendant.
H. Ernesto Castillo, CA Bar No. 220900 One Kaiser Plaza, Suite 2300 Attorney for Defendant GERARDO CASTILLO CHRISTINE WONG Attorney for the UNITED STATES OF AMERICA
H. Ernesto Castillo, CA Bar No. 220900
One Kaiser Plaza, Suite 2300
Attorney for Defendant GERARDO CASTILLO
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
Defendant Gerardo Castillo, by and through his undersigned counsel and the United States of America, through Assistant United States Attorney Christine Wong, hereby stipulate that the Court vacate the further status conference in the above captioned case currently set for October 4, 2011, at 2:30 p.m., and continue it to October 18, 2011, at 2:30 p.m. It is further requested that the Court exclude time under the Speedy Trial Act between October 4, 2011 to October 18, 2011.
The parties are currently engaged in plea discussions, and the defendant requests additional time to review discovery and investigate the charges filed by the Government. Additionally, defense counsel is scheduled to being a murder trial, People v. Samuel Garcia, in Alameda County. This is a no time waiver, co-defendant case.
To allow the parties to continue plea discussions and for defendant to continue preparation of his defense, the parties request that this matter be set on October 18, 2011, at 2:30 p.m. for further status conference. The parties further stipulate and agree that the time between October 4, 2011, and October 18, 2011, should be excluded under the Speedy Trial Act for effective preparation and continuity of counsel, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv).
SO STIPULATED:
H. ERNESTO CASTILLO
Attorney for GERARDO CASTILLO
CHRISTINE WONG
Attorney for the UNITED STATES OF AMERICA
IT IS SO ORDERED
HONORABLE RICHARD SEEBORG
U.S. District Judge