Opinion
Case No. 1:11-cr-00348 AWI-1
01-13-2012
UNITED STATES OF AMERICA, Plaintiff, v. JACOB ASA GAMBOA, Defendant.
BENJAMIN B. WAGNER United States Attorney BRIAN W. ENOS Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender JEREMY S. KROGER Assistant Federal Defender Attorney for Defendant Jacob Asa Gamboa
DANIEL J. BRODERICK, Bar #89424
Federal Defender
JEREMY S. KROGER, Bar # 258956
Assistant Federal Defender
Designated Counsel for Service
Attorney for Defendant
JACOB ASA GAMBOA
STIPULATION & ORDER TO CONTINUE STATUS CONFERENCE
Dept : Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective attorneys of record herein, that the status conference hearing in the above-referenced action now scheduled for January 17, 2012, may be continued to February 21, 2012 at 9:00 a.m.
The government has recently provided a plea offer to the defense and the parties are engaged in negotiations concerning the terms of the offer. Additional investigation, research and negotiations are necessary to determine the applicability of the enhancements. The requested continuance will conserve time and resources for all parties and the Court.
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).
BENJAMIN B. WAGNER
United States Attorney
By: Brian W. Enos
BRIAN W. ENOS
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
By: Jeremy S. Kroger
JEREMY S. KROGER
Assistant Federal Defender
Attorney for Defendant
Jacob Asa Gamboa
ORDER
IT IS SO ORDERED. Time is excluded in the interests of justice pursuant to 18 U.S.C.
§§ 3161(h)(7)(A) and (B).
____________________________
CHIEF UNITED STATES DISTRICT JUDGE