Opinion
Case No.: 2:09 CR 380-08 WBS
01-20-2012
UNITED STATES OF AMERICA, Plaintiff, v. JOSE MANUEL VERA GIL, Defendant
DANNY D. BRACE, JR., #114466 LAW OFFICE OF DANNY D. BRACE, JR. Attorney for Jose Vera Gil
DANNY D. BRACE, JR., #114466
LAW OFFICE OF DANNY D. BRACE, JR.
Attorney for Jose Vera Gil
STIPULATION AND ORDER TO EXTEND TIME FOR JUDGMENT AND SENTENCING AND TO EXCLUDE TIME
The parties agree that time beginning January 23, 2011 and extending through January 30, 2012 should be excluded from the calculation of time under the Speedy Trial Act. (T-2 and T-4). The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and so that the defendant may have continuity of counsel. 18 U.S.C. § 3161(h)(8)(B)(iv). Additionally, the above named counsel is currently in a trial in Sacramento County Superior Court, People v. Phil Reese, Department 29, and has not been given authority by the Judge in that court to attend other court hearings. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(8)(A).
The parties further request that this matter be taken off the January 23, 2012, calendar and be rescheduled to January 30, 2012 at 9:30 a.m.
Respectfully submitted,
By: ___________________________
DANNY D. BRACE, JR.,
Attorney for Tevin Tan
By: ___________________________
Authorized to sign for Mr. Beckwith
On January 19, 2012
MICHAEL BECKWITH
Assistant U.S. Attorney
IT IS SO ORDERED:
___________________________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE