Opinion
No. CR-S-10-371 JAM
09-22-2011
UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARIA GUTIERREZ, Defendant.
JOHN R. MANNING Attorney for Defendant Jose Maria Gutierrez Benjamin B. Wagner United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
Attorney for Defendant
JOSE MARIA GUTIERREZ
STIPULATION AND
[PROPOSED ORDER] CONTINUING
STATUS CONFERENCE
Time: 9:30 a.m.
Judge: Honorable John A. Mendez
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Heiko P. Coppola, Assistant United States Attorney, together with counsel for defendant Jose Maria Gutierrez, John R. Manning, Esq., that the status conference presently set for September 27, 2011 be continued to November 1, 2011, at 9:30 a.m., thus vacating the presently set status conference.
The requested continuance is based upon the need for defense to review the anticipated plea agreement, discuss it with the defendant, research guidelines applicable to the anticipated plea agreement and prepare the defendant to enter a guilty plea. Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, November 1, 2011.
IT IS SO STIPULATED.
JOHN R. MANNING
Attorney for Defendant
Jose Maria Gutierrez
Benjamin B. Wagner
United States Attorney
HEIKO P. COPPOLA
Assistant U.S. Attorney
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
Attorney for Defendant
JOSE MARIA GUTIERREZ
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff,
v.
JOSE MARIA GUTIERREZ, Defendant.
No. CR-S-10-0371 JAM
ORDER TO
CONTINUE STATUS CONFERENCE
GOOD CAUSE APPEARING, it is hereby ordered that the September 27, 2011 status conference be continued to November 1, 2011 at 9:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161(h)(7)(A) and Local Code T4 from the date of this order to November 1, 2011.
IT IS SO ORDERED.
John A. Mendez
United States District Court Judge