Opinion
2:11-CR-00102 LKK
08-23-2011
UNITED STATES OF AMERICA, Plaintiff, v. HERNAN RAMIREZ-RAMIREZ, et al., Defendants.
Respectfully submitted, DANIEL J. BRODERICK Federal Defender MATTHEW M. SCOBLE Assistant Federal Defender Attorney for Defendant HERNAN RAMIREZ-RAMIREZ GILBERT ROQUE, Esq. Attorney for Defendant DANIEL VARGAS SALINAS BENJAMIN B. WAGNER United States Attorney MICHAEL ANDERSON Assistant U.S. Attorney Attorney for Plaintiff
DANIEL J. BRODERICK, Bar# 89424
Federal Defender
MATTHEW M. SCOBLE, Bar# 237432
Assistant Federal Defender
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone (916) 498-5700
Attorney for Defendant
HERNAN RAMIREZ-RAMIREZ
STIPULATION AND [PROPOSED]
ORDER
JUDGE: Hon. Lawrence K. Karlton
It is hereby stipulated and agreed to between the United States of America through MICHAEL ANDERSON, Assistant U.S. Attorney, and defendant, HERNAN RAMIREZ-RAMIREZ, by and through his counsel, MATTHEW M. SCOBLE, Assistant Federal Defender, DANIEL VARGAS SALINAS, by and through his counsel, GILBERT ROQUE, that the status conference set for Tuesday, August 23, 2011, be continued to Tuesday, September 20, 2011, at 9:15 a.m.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendants, to examine possible defenses and to continue investigating the facts of the case.
It is further stipulated that the time period from the date of this stipulation, through and including the date of the new status conference hearing, September 20, 2011, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. §§ 3161 (h)(7)(A) & (B)(iv)and Local Code T4 [reasonable time for defense counsel to prepare].
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
MATTHEW M. SCOBLE
Assistant Federal Defender
Attorney for Defendant
HERNAN RAMIREZ-RAMIREZ
GILBERT ROQUE, Esq.
Attorney for Defendant
DANIEL VARGAS SALINAS
BENJAMIN B. WAGNER
United States Attorney
MICHAEL ANDERSON
Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
Based on the stipulation of the parties and good cause appearing therefrom, the Court hereby adopts the stipulation of the parties in its entirety as its order. It is hereby ordered that the presently set August 23, 2011, status conference shall be continued to September 20, 2011, at 9:15 a.m. It is further ordered that the time period from the date of the parties' stipulation, August 18, 2011, through and including the date of the new status conference hearing, September 20, 2011, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161 (h)(7)(A) & (B)(iv) and Local Code T4 [reasonable time for defense counsel to prepare].
Based on the stipulation of the parties and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case would deny defense counsel reasonable time for effective preparation taking into account the exercise of due diligence. The Court specifically finds that the ends of justice served by the granting of such continuance outweigh the interests of the public and the defendants in a speedy trial.
IT IS SO ORDERED.
LAWRENCES K. KARLTON
SENIOR JUDGE
UNITED STATES DISTRICT COURT