Opinion
No. 1:11-cr-00080 AWI
10-17-2011
BENJAMIN B. WAGNER United States Attorney HENRY CARBAJAL Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender CHARLES J. LEE Assistant Federal Defender Attorney for Defendant ERIC HUGGINS
DANIEL J. BRODERICK, Bar #89424
Federal Defender
CHARLES J. LEE, Bar #221057
Assistant Federal Defender
Designated Counsel for Service
Attorney for Defendant
ERIC HUGGINS
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE HEARING
DATE: December 12, 2011
TIME: 10:00 A.M.
JUDGE: Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for October 24, 2011, may be continued to December 12, 2011 at 10:00 a.m.
This continuance is at the request of defense counsel as defense needs additional time in preparation of this case. Defense anticipates the government will send a plea agreement over this week. Additional time will then be needed to review the agreement, make the appropriate guideline calculations, to consult with the client, and potentially to make a counter-offer.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation and plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
HENRY CARBAJAL
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
CHARLES J. LEE
Assistant Federal Defender
Attorney for Defendant
ERIC HUGGINS
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
IT IS SO ORDERED.
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CHIEF UNITED STATES DISTRICT JUDGE