Opinion
No. 11-225 WBS
08-25-2011
UNITED STATES OF AMERICA, Plaintiff, v. KARINA JUAREZ, RAMIRO LOPEZ, Defendants.
DINA L. SANTOS Attorney for Defendant KARINA JUAREZ CHRIS COSCA Attorney for Defendant RAMIRO LOPEZ MICHAEL ANDERSON Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
A Professional Law Corp.
Attorney for Defendant
ERNESTO SOTO-GONZALEZ
STIPULATION AND ORDER VACATING
DATE, CONTINUING CASE, AND EXCLUDING TIME
Date: Sept. 12, 2011
Time: 8:30 a.m.
Judge: Honorable Judge Shubb
IT IS HEREBY STIPULATED by and between Assistant United States Attorney MICHAEL ANDERSON, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant KARINA JUAREZ; Attorney CRIS COSCA, Counsel for RAMIRO LOPEZ; that the status conference scheduled for August 29, 2011, be vacated and the matter be continued to this Court's criminal calendar on September 12, 2011, at 8:30 a.m, for further status.
This continuance is requested by the defense in order to permit further client consultation concerning a possible plea agreement and further negotiations with the prosecution. The defense is also engaged in ongoing investigation.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.
The Court is advised that all counsel have conferred about this request, that they have agreed to the September 12, 2011 date, and that all counsel have authorized Ms. Santos to sign this stipulation on their behalf.
IT IS SO STIPULATED.
DINA L. SANTOS
Attorney for Defendant
KARINA JUAREZ
CHRIS COSCA
Attorney for Defendant
RAMIRO LOPEZ
MICHAEL ANDERSON
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
By the Court,
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE