Opinion
CASE NO. 1:08-CR-00232 LJO
10-20-2011
Respectfully submitted, BENJAMIN B. WAGNER United States Attorney KIMBERLY A. SANCHEZ Assistant U.S. Attorney JON RENGE Attorney for Curtis Hendrix
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 by and between Benjamin B. Wagner, United States Attorney and Kimberly A. Sanchez, Assistant U.S. Attorney and Jon Renge, attorney for Curtis Hendrix, that hearing currently set for October 21, 2011 and related motions schedule be vacated. The parties further request that the trial set for November 7, 2011 be continued to Tuesday, March 13, 2012. Upon closer inspection of discovery in preparation for trial, the defendant is considering filing additional motions that require additional investigation, and is reconsidering entering into a negotiated plea agreement with the government. Moreover, based upon medical reasons set forth by the government in camera to the Court and defense counsel, the government is also requesting that the trial be continued. The parties have consulted regarding the amount of additional time necessary based upon the above reasons as well as to insure continuity of counsel for the defendant. 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
KIMBERLY A. SANCHEZ
Assistant U.S. Attorney
JON RENGE
Attorney for Curtis Hendrix
Good Cause is present, both for the continuance and the exclusion of time. The requests are granted. IT IS SO ORDERED.
Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE