Opinion
No. 2:10-CR-0468 JAM
07-16-2012
UNITED STATES OF AMERICA, Plaintiff, v. JOSE PENA, et. al. Defendants.
JESSE I. SANTANA Attorney for Defendant Leonardo Contreras ERIN RADEKIN Attorney for Defendant Damian Cervantes HEIKO P. COPPOLA Assistant U.S. Attorney Attorney for Plaintiff
Jesse I. Santana (State Bar No. 132803)
The Santana Law Firm
The Historic Winship Building
Attorney for Defendant
Leonardo Contreras
STIPULATION AND ORDER TO EXCLUDE TIME
Hon. John A. Mendez
Plaintiff, United States of America, by and through it's counsel, Assistant United States Attorney Heiko P. Coppola; Damion C. Cervantes, by and through his counsel, Erin J. Radekin; and Leonardo Contreras, by and through his counsel, Jesse I. Santana, agree and request to stipulate to the current status conference in this case be continued from July 17, 2012 at 9:30 a.m. to August 14, 2012 at 9:45 a.m. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendants may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h) (7) (B) (iv) and Local Code T-4.
Defense counsel needs additional time to conduct further investigation in this case and also discuss recent settlement offers that have been extended to the defendants. For these reasons, the parties jointly request a new status conference date, and that the time period from July 17, 2012, to and including August 14, 2012 be excluded under the Speedy Trial Act pursuant to 18 U.S.C. Section 3161 (h) (8) (B) (iv) and Local Code T4 for defense preparation and based on a finding by the Court that the ends of justice served by granting a continuance outweigh the best interest of the public and defendants in a speedy trial.
Respectfully submitted,
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JESSE I. SANTANA
Attorney for Defendant
Leonardo Contreras
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ERIN RADEKIN
Attorney for Defendant
Damian Cervantes
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HEIKO P. COPPOLA
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Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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JOHN A. MENDEZ
U.S. DISTRICT COURT JUDGE
UNITED STATES DISTRICT COURT