Opinion
Case No.: 2:12 MJ 00011 EFB
01-25-2012
UNITED STATES OF AMERICA, Plaintiff, v. JUVANY HERRERA-FELIX Defendant
DANNY D. BRACE, JR., Attorney for Juvany Herrera-Felix Authorized to sign for Mr. Leras On January 25,2012 TODD LERAS Assistant U.S. Attorney
DANNY D. BRACE, JR., #114466
LAW OFFICE OF DANNY D. BRACE, JR.
Attorney for Juvany Herrera-Felix
STIPULATION AND ORDER TO EXTEND TIME FOR HEARING AND TO EXCLUDE TIME
The parties agree that time beginning January 27, 201 and extending through February 13,2012 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). 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).
Defendant Juvany Herrera-Felix has just been released on a secured $150,000.00 appearance bond and waives time for continuance of the Preliminary Hearing to February 13, 2012..
The parties further request that this matter be taken off the January 27,2012, Magistrate Judge Drozd's calendar and be rescheduled to Magistrate Judge Newman's February 13,2012 calendar at 2:00 p.m..
Respectfully submitted,
By: _________
DANNY D. BRACE, JR.,
Attorney for
Juvany Herrera-Felix
By: _________
Authorized to sign for Mr. Leras
On January 25,2012
TODD LERAS
Assistant U.S. Attorney
IT IS SO ORDERED:
____________
HON. DALE A. DROZD
Magistrate Judge U.S. District Court
Eastern District of California