Opinion
CASE NO. CR-S-11-289 WBS
08-31-2011
UNITED STATES OF AMERICA, Plaintiff, v. ANTONIO MORENO-NANEZ FERNANDO MORENO-CAMACHO, Defendants.
Lexi Negin for TODD PICKLES Assistant U.S. Attorney Attorney for United States LEXI NEGIN Assistant Federal Defender Attorney for Antonio Moreno-Nanez Lexi Negin for Scott N. Cameron Attorney for Fernando Moreno-Camacho
DANIEL BRODERICK, Bar #89424
Federal Defender
Lexi Negin, Bar #250376
Assistant Federal Defender
Attorney for Defendant
ANTONIO MORENO-NANEZ
STIPULATION AND PROPOSED ORDER TO CONTINUE STATUS HEARING, SET
MOTION SCHEDULE AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL
ACT
This case is currently scheduled for a status hearing on September 12, 2011. The parties agree that additional time is needed for defense preparation and for the drafting of motions to suppress. In addition, the parties have agreed to a briefing schedule for defense counsel to file a Motion to Suppress Evidence as follows:
Defendant's Motion due: September 19, 2011
Government Opposition due: October 3, 2011
Defendant Reply due: October 11, 2011
Non-evidentiary hearing/status: October 17, 2011
The parties, through their respective counsel, hereby stipulate and agree that the status conference scheduled in this case be continued until October 17, 2011. In addition, the parties stipulate that the time period from August 31, 2011, to October 17, 2011, be excluded under the Speedy Trial Act (18 U.S.C. §3161(h)(8)(B)(iv) and Local Code T4), due to the need to provide defense counsel with the reasonable time to prepare.
A proposed order is attached and lodged separately for the court's convenience.
Respectfully submitted,
BENJAMIN WAGNER
United States Attorney
DANIEL BRODERICK
Federal Defender
Lexi Negin for
TODD PICKLES
Assistant U.S. Attorney
Attorney for United States
LEXI NEGIN
Assistant Federal Defender
Attorney for Antonio Moreno-Nanez
SCOTT N. CAMERON
Lexi Negin for
Scott N. Cameron
Attorney for Fernando Moreno-Camacho
UNITED STATES OF AMERICA, Plaintiff,
v.
ANTONIO MORENO-NANEZ
FERNANDO MORENO-CAMACHO, Defendants.
CASE NO. CR-S-11-289 WBS
PROPOSED ORDER CONTINUING STATUS HEARING, EXCLUDING TIME PURSUANT
TO THE SPEEDY TRIAL ACT, AND SETTING MOTION SCHEDULE
For the reasons set forth in the stipulation of the parties, filed on August 31, 2011, IT IS HEREBY ORDERED that the status conference currently scheduled for September 12, 2011, be vacated and that the case be set for Monday, October 17th, at 8:30 a.m. IT IS FURTHER, ORDERED that the following briefing schedule is set:
Defendant's Motion due: September 19, 2011
Government Opposition due: October 3, 2011
Defendant Reply due: October 11, 2011
Non-evidentiary hearing/status: October 17, 2011
The Court finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that, for the reasons stated in the parties' August 31, 2011 stipulation, the time under the Speedy Trial Act is excluded from August 31, 2011, through October 17, 2011, pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) and Local Code T4, due to the need to provide defense counsel with the reasonable time to prepare.
WILLIAM B. SHUDD
UNITED STATES DISTRICT JUDGE