Opinion
Case No.: 97-CR-05225 LJO
09-15-2011
UNITED STATES OF AMERICA, Plaintiff, v. BRUCE DANIELS, Defendant,
DAVID A. TORRES Attorney for Defendant BRUCE DANIELS KEVIN P. ROONEY Assistant U. S. Attorney
LAW OFFICE OF DAVID A. TORRES
Attorney at Law, SBN 135059
Attorney for Defendant
BRUCE DANIELS
STIPULATION AND ORDER TO CONTINUE SENTENCING HEARING
TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE: LAWRENCE J. O'NEILL AND KEVIN P. ROONEY, ASSISTANT UNITED STATES ATTORNEY:
COMES NOW Defendant, BRUCE DANIELS by and through his attorney of record, DAVID A. TORRES hereby request that the status conference hearing date currently set for Friday, September 23, 2011 be continued to October 28, 2011 at 9:00 a.m., or a date convenient to court and counsel.
This is a mutual agreement between myself, and Assistant United States Attorney Kevin P. Rooney. I have been in communication with AUSA Kevin P. Rooney and we both feel that it is in the best interest of my client to continue the sentencing.
The defendant is willing to continue excluding time through the next court appearance and that the ends of justice in the exclusion outweigh defendant's speedy trial rights.
Based upon the foregoing, I respectfully request that this matter be continued to October 28, 2011.
The parties also agree that the delay resulting from the continuance shall be excluded in the interest of justice pursuant to 18 U.S.C. §3161 (h)(7)(A) and §3161 (h)(7)(B)(i) & (iv).
DAVID A. TORRES
Attorney for Defendant
BRUCE DANIELS
KEVIN P. ROONEY
Assistant U. S. Attorney
ORDER
IT IS SO ORDERED. Time is excluded in the interest of justice pursuant to 18 U.S.C. §3161(h)(7)(A) and §3161 (h)(7)(B)(i) & (iv).
LAWRENCE J. O'NEILL
United States District Judge