Opinion
No. CR-11-00546 SBA
10-28-2011
UNITED STATES OF AMERICA, Plaintiff, v. JUAN MORA, Defendant.
MELINDA HAAG (CABN 132612) United States Attorney MIRANDA KANE (CABN 150630) Chief, Criminal Division KAREN D. BEAUSEY (CABN 155258) Assistant United States Attorney Attorneys for Plaintiff
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
KAREN D. BEAUSEY (CABN 155258)
Assistant United States Attorney
Attorneys for Plaintiff
STIPULATION AND ORDER SET DATE FOR CHANGE OF PLEA
IT IS HEREBY STIPULATED, by and between the parties to this action, that the date for the defendant's change of plea shall be set as November 16, 2011 at 11:00 a.m.
Because change of plea is a critical event in a criminal case, it is necessary to pick a date that ensures that defense counsel can be present. In addition, it is preferable that the government attorney responsible for prosecuting the case be present for change of plea. November 16, 2011 is the first date that is available to the Court, government counsel, and defense counsel. Accordingly, the parties further stipulate and agree that the time between October 25, 2011 and November 16, 2011 should be excluded, pursuant to under18 U.S.C. §§3161(H)(7)(A) and (B)(iv), when computing the time within which trial in this matter must commence, because the ends of justice outweigh the bests interests of the public and the defendant in a speedy and public trial in that setting the matter at an earlier date would unreasonably deny the government or the defendant continuity of counsel.
Jesse Garcia, Esq.
Garcia, Schnayerson & Thompson
Counsel for defendant MORA
Karen Beausey
Assistant United States Attorney
I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document.
Karen Beausey
Counsel for the Unites States
ORDER
IT IS HEREBY ORDERED that the date for the defendant's change of plea shall be set as November 16, 2011 at 11:00 a.m.
The Court finds that the ends of justice outweigh the bests interests of the public and the defendant in a speedy and public trial, in that for the reasons set forth above, setting the matter at an earlier date would unreasonably deny the government or the defendant continuity of counsel. Based on these findings, IT IS HEREBY ORDERED THAT all time is excluded from October 26, 2011 until November 16, 2011 pursuant to 18 U.S.C. §§3161(h)(7)(A) and (B)(iv).
IT IS SO ORDERED.
HON. SAUNDRA BROWN ARMSTRONG
UNITED STATES DISTRICT JUDGE