Opinion
No. CR-S-11-348 LKK
09-27-2011
THE UNITED STATES OF AMERICA, Plaintiff, v. JUVENAL MATA-CHAVEZ, MARCELO RANGEL-MONGEL, AGUSTIN MERCADO-VALDOVINOS, MIGUEL ANGEL RUIZ and GUILLERMO PINEDA-SOLORIO, Defendants.
MICHAEL D. LONG (CA State Bar #149475) Attorney for JUVENAL MATA-CHAVEZ Respectfully submitted, MICHAEL D. LONG Attorney for Mr. Mata-Chavez CLEMENTE JIMENEZ Attorney for Mr. Rangel-Mongel OLAF HEDBERG Attorney for Mr. Mercado-Valdovinos KELLY BABINEAU Attorney for Mr. Angel-Ruiz ERIN RADEKIN Attorney for Mr. Pineda-Solario BENJAMIN WAGNER United States Attorney HEIKO COPPOLA Assistant U.S. Attorney
MICHAEL D. LONG (CA State Bar #149475)
Attorney for JUVENAL MATA-CHAVEZ
STIPULATION AND
ORDER TO CONTINUE THE STATUS
CONFERENCE
Judge: Hon.
It is hereby stipulated between the parties, Assistant United States Attorney Heiko Coppola, Michael Long, attorney for JUVENAL MATA-CHAVEZ, Clemente Jimenez, attorney for MARCELO RANGEL-MONGEL, Olaf Hedberg, attorney for AGUSTIN MERCADO-VALDOVINOS , Kelly Babineau, attorney for MIGUEL ANGEL RUIZ , and Erin Radekin, attorney for GUILLERMO PINEDA-SOLORIO, that the status conference date of September 27, 2011, should be continued until October 25, 2011.
Defense counsel just received a large amount of discovery. Each defense attorney needs time to review the discovery and then meet with his or her client concerning the materials. Each attorney then must negotiate with the prosecutor on behalf of his or her client.
IT IS STIPULATED that the period of time from the signing of this Order up to and including the new status conference date of October 25, 2011, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, for ongoing preparation of counsel. Each party stipulates that each defendant's need for additional time to review the discovery outweighs each defendant's, and the public's need for a speedy trial. Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interest of the public and of all the defendants in a speedy trial and that each party would like time to be excluded as provided by Local Code T4 from today's date through October 25, 2011.
Respectfully submitted,
MICHAEL D. LONG
Attorney for Mr. Mata-Chavez
CLEMENTE JIMENEZ
Attorney for Mr. Rangel-Mongel
OLAF HEDBERG
Attorney for Mr. Mercado-Valdovinos
KELLY BABINEAU Attorney for Mr. Angel-Ruiz
ERIN RADEKIN
Attorney for Mr. Pineda-Solario
BENJAMIN WAGNER
United States Attorney
HEIKO COPPOLA
Assistant U.S. Attorney
MICHAEL D. LONG (CA State Bar #149475)
THE UNITED STATES OF AMERICA, Plaintiff,
v.
JUVENAL MATA-CHAVEZ, MARCELO RANGEL-MONGEL,
AGUSTIN MERCADO-VALDOVINOS,
MIGUEL ANGEL RUIZ and GUILLERMO PINEDA-SOLORIO, Defendants.
No. CR-S-11-348 LKK
ORDER
Date: 10-25-11
Time: 9:15 a.m.
Judge: Hon. Lawrence K. Karlton
UPON GOOD CAUSE SHOWN and the stipulation of the parties, it is ordered that the status conference presently set for September 27, 2011, at 9:15 a.m. be continued to October 25, 2011, at 9:15 a.m. Based on the representations of counsel and good cause appearing therefrom, the Court hereby finds that the granting a continuance in this case will permit each attorney to effectively represent his or her client by giving each attorney adequate time to review the recently provided discovery and then to consult with his or her client. The ends of justice served by granting such continuance outweigh the best interest of the public and of all the defendants in a speedy trial.
The period of time from September 23, 2011, up to and including the new status conference date of October 25, 2011, is excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, for ongoing preparation of counsel.
LAWRENCE K. KARLTON
SENIOR JUDSE
UNITED STATES DISTRICT COURT