Opinion
CASE NO. 1:11-CR-00376 LJO
01-19-2012
UNITED STATES OF AMERICA, Plaintiff, v. ZEFERINA SALGADO GUZMAN DE CORTEZ, VICTORINO EPIFANIO BAZANTE PACHECO, and FLORENCIO MORALES-SOLANO, Defendants.
BENJAMIN B. WAGNER United States Attorney KIMBERLY A. SANCHEZ Assistant U.S. Attorney
BENJAMIN B. WAGNER
United States Attorney
KIMBERLY A. SANCHEZ
Assistant U.S. Attorney
STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE
IT IS HEREBY STIPULATED and requested by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and Rudy Banuelos, attorney for Zeferina Salgado Guzman de Cortez; Roger Litman, attorney for Victorino Epifanio Bazante Pacheco; and H. Ty Kharazi, attorney for Florencio Morales-Solano that the status conference set for January 23, 2012 be continued to April 2, 2012. The parties further stipulate and request that the Court set March 26, 2012 as the due date for the Government's response to defendants Zeferina Salgado Guzman de Cortez's and Florencio Morales-Solano's motions for discovery. The government has provided additional discovery after the filing of the defendants' motions, and the parties have agreed to further review the discovery provided to determine what outstanding discovery issues exist and to discuss proposed resolutions to the cases. The parties need additional time to accomplish those goals. Additionally, the parties have communicated with respect to a date that all counsel are available to appear in Court, and the earliest possible date is April 2, 2012. The parties further request the Court to enter an Order finding that the "ends of justice" served by a continuance outweigh the interest of the public and the defendant in a speedy trial, and that the delay occasioned by such continuance is excluded from the
Act's time limits pursuant to 18 U.S.C. § 3161(h)(8)(A).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By ___________________________
KIMBERLY A. SANCHEZ
Assistant U.S. Attorney
___________________________
RUDY BANUELOS
Attorney for Zeferina Salgado
Guzman de Cortez
___________________________
ROGER LITMAN
Attorney for Victorino Epifanio
Bazante Pacheco
___________________________
H. TY KHARAZI
Attorney for Florencio Morales
Solano
Good cause exists. Time is excluded. IT IS SO ORDERED.
Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE