Opinion
No. 2:09-cr-00381 EJG
10-06-2011
UNITED STATES OF AMERICA, Plaintiff, v. GERARDO VALENCIA REVUELTA, Defendants.
ROBERT L. FORKNER Attorney for Defendant MICHAEL M. BECKWITH Assistant United States Attorney
ROBERT L. FORKNER (CSB#1066097)
Law Offices of Robert L. Forkner
Attorney for Defendant
GERARDO VALENCIA-REVUELTA
STIPULATION AND ORDER
**as modified
The defendant, GERARDO VALENCIA-REVUELTA, through his attorney ROBERT L. FORKNER, and the United States, through its counsel, Assistant United States Attorney MICHAEL M. BECKWITH, hereby stipulate and request the following:
1. That the Court change the sentencing in the above-captioned case from October 7, 2011, to December 2, 2011, at 10:00 a.m. **
2. The parties have been unable to coordinate a meeting for a safety valve debrief.
3. Further, the continuance is needed to allot the parties enough time to resolve issues related to the defendant's roll in the offense.
4. The Senior United States Probation Officer, Casey Horner, SR. has no objections to the continuance.
For these reasons, both parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from October 7, 2011 through December 2, 2011, for case resolution under 18 U.S.C. § 3161(h)(7)(B)(iv).
Respectfully submitted,
ROBERT L. FORKNER
Attorney for Defendant
MICHAEL M. BECKWITH
Assistant United States Attorney
ORDER
IT IS SO ORDERED. For the reasons stated above, the Court finds that the needs of defense counsel to prepare outweigh the public and the defendants' interest in a speedy trial, and therefore the date, change of hearing, and exclusion of time are in the interest of justice.
Honorable Edward J. Garcia
Senior United States District Judge