Opinion
No. 10-CR-502
08-25-2011
UNITED STATES OF AMERICA Plaintiff, v. JUAN HERNANDEZ-LOPEZ Defendant.
Respectfully submitted, By Olaf W. Hedberg, Attorney at Law Attorney for Juan Hernandez-Lopez Benjamin B. Wagner United States Attorney Olaf Hedberg for Michele Beckwith Michele Beckwith Assistant U.S. Attorney
Olaf W. Hedberg, SBN #151082
Olaf W. Hedberg, Attorney at Law
Attorney for Defendant
STIPULATION AND [PROPOSED
ORDER].
Judge: Hon. Garland E. Burrell, Jr.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, MICHELE BECKWITH , Assistant Untied States Attorney, attorney for Plaintiff, OLAF HEDBERG, attorney for JUAN HERNANDEZ-LOPEZ., that the status conference now scheduled for August 26, 2011 at 9:00 am be vacated and a new date of September 16, 2011 at 9:00 am be set for a change of plea. The parties have been negotiating the terms of a proposed plea agreement and will continue to actively do so.
It is further stipulated and agreed between the parties that the period beginning August 26, 2011 and ending September 16, 2011 , should be excluded in computing the time within which the trial of the above criminal prosecution must commence for the purpose of the Speedy Trial Act for defense preparation. Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code 3161(h)(7)(B)(iv) (continuity of counsel/reasonable time for effective preparation, specifically the continuance is requested to allow counsel time to review discovery and conduct investigation) 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, September 16, 2011.
Respectfully submitted,
By Olaf W. Hedberg, Attorney at Law
Attorney for Juan Hernandez-Lopez
Benjamin B. Wagner
United States Attorney
Olaf Hedberg for Michele Beckwith
Michele Beckwith
Assistant U.S. Attorney
ORDER
IT IS SO ORDERED
GARLAND E. BURRELL, JR.
United States District Judge