Opinion
CASE NO. CR S-11-00069 - JAM
01-09-2012
UNITED STATES OF AMERICA, Plaintiff, v. SERGIO COBIAN, Defendant.
Kyle R. Knapp Attorney for Defendant, Sergio Cobian William S. Wong Assistant U.S. Attorney Attorney for Plaintiff
KYLE R. KNAPP
Attorney at Law
Attorney for Sergio Cobian
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE,
AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, William S. Wong, Assistant United States Attorney, attorney for plaintiff; Kyle Knapp, attorney for defendant, SERGIO COBIAN, that the previously scheduled status conference date of January 10, 2012, be vacated and the matter set for status conference on January 31, 2012 at 9:30 a.m.
This continuance is requested to allow counsel additional time to arrive at a plea agreement. Mr. Wong and I are exchanging documentation that should lead to a resolution in this matter and we respectfully need a bit more time to resolve this case.
Accordingly, counsel and the defendant agree that time under the Speedy Trial Act from the date this stipulation is lodged, through January 31, 2012, should be excluded in computing time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. §§ 3161 (h)7(A) and B(iv), and Local Code T4[reasonable time for defense counsel to prepare].
Respectfully submitted.
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Kyle R. Knapp
Attorney for Defendant, Sergio Cobian
Respectfully submitted.
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William S. Wong
Assistant U.S. Attorney
Attorney for Plaintiff
SO ORDERED.
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HON. JOHN A. MENDEZ
JUDGE
UNITED STATES DISTRICT COURT