Opinion
No. 4:12-cr-00878-YGR-1
05-01-2013
UNITED STATES OF AMERICA, Plaintiff, v. DENISE LASHAWN REED, Defendant.
Robert J. Beles, Cal. Bar No. 41993 H. Ernesto Castillo, Cal. Bar No. 220900 Attorney for Defendant DENISE LASHAWN REED CYNTHIA LEWIS STIER Attorney for the UNITED STATES OF AMERICA
Robert J. Beles, Cal. Bar No. 41993
H. Ernesto Castillo, Cal. Bar No. 220900
Attorney for Defendant DENISE LASHAWN REED
STIPULATION AND ORDER
TO CONTINUE STATUS CONFERENCE
Defendant DENISE LASHAWN REED, by and through her undersigned counsel and the United States of America, through Assistant United States Attorney CYNTHIA LEWIS STIER, hereby stipulate that the Court vacate the further status conference in the above captioned case currently set for Thursday, May 2, at 2:00 p.m., and continue it to June 6, 2013, at 2:00 p.m. It is further requested that the Court exclude time under the Speedy Trial Act between March 14, 2013, when the parties last appeared before this Court, and June 6, 2013.
The parties are currently engaged in plea discussions, and the defendant requests additional time to review discovery and investigate the charges filed by the Government. Defense counsel is currently scheduled to begin a jury trial on People v. Mosqueda, Case No. H51281, in the county of Alameda on May 1, 2013. This case is a multiple count 288(A) case in which multiple witnesses have been subpoenaed to testify and is expected to last approximately three weeks. Additionally, defense counsel is expecting the birth of his second child on May 23, 2013 and will be taking one week of family leave beginning on that date through May 31, 2013.
To allow the parties to continue plea discussions and for defendant to continue preparation of her defense, the parties respectfully request that the status conference set for Thursday, May 2, 2013 at 2:00 p.m. be vacated and that this matter be reset to Thursday, June 6, 2013, at 2:00 p.m. for further status conference. The parties further stipulate and agree that the time between March 14, 2013, and June 6, 2013, should be excluded under the Speedy Trial Act for effective preparation and continuity of counsel, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv).
IT IS SO STIPULATED.
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H. ERNESTO CASTILLO
Attorney for DENISE LASHAWN REED
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ROBERT J. BELES
Attorney for DENISE LASHAWN REED
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CYNTHIA LEWIS STIER
Attorney for the UNITED STATES OF AMERICA
IT IS SO ORDERED.
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HON. YVONNE GONZALEZ ROGERS
United States District Judge