Opinion
No. 2:11-MJ-00293-KJN
10-12-2011
UNITED STATES OF AMERICA, Plaintiff, v. JAIME MADERA, Defendant.
DANIEL J. BRODERICK Federal Defender LINDA C. HARTER Chief Assistant Federal Defender Attorney for Defendant JAIME MADERA DAVID J. GALLEGOS Certified Student Attorney BENJAMIN B. WAGNER United States Attorney DAVID STEVENSON Special Assistant U.S. Attorney
DANIEL J. BRODERICK, #89424
Federal Defender
LINDA C. HARTER, CA Bar #179741
Chief Assistant Federal Defender
Designated Counsel for Service
DAVID J. GALLEGOS Certified Student Attorney
Attorney for Defendant
JAIME MADERA
STIPULATION TO CONTINUE AND EXCLUDE TIME
Judge: Hon. Kendall J. Newman
IT IS HEREBY STIPULATED between the parties through their respective counsel, David Stevens, Special Assistant United States Attorney, and Linda C. Harter, Chief Assistant Federal Defender, attorney for JAIME MADERA, and Certified Student Attorney, David J. Gallegos, that the Court vacate the Court Trial on October 24, 2011 at 9:00 a.m. and set the Court Trial for November 14, 2011 at 9:00 a.m.
This continuance is requested because the parties are in the process of plea negotiation. The parties need more time to reach a plea agreement. The parties further agree that the time should be excluded from the date of this [Proposed] Order until the Court Trial which is set for November 14, 2011, pursuant to 18 U.S.C. Section § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare). 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. Section § 3161(h)(7)(A).
DANIEL J. BRODERICK
Federal Defender
LINDA C. HARTER
Chief Assistant Federal Defender
Attorney for Defendant
JAIME MADERA
DAVID J. GALLEGOS
Certified Student Attorney
BENJAMIN B. WAGNER
United States Attorney
DAVID STEVENSON
Special Assistant U.S. Attorney
ORDER
IT IS SO ORDERED.
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE