Opinion
No. 2:06-CR-0264 WBS
09-12-2011
Assistant Federal Defender Attorney for ADRIAN REYNOSO BENJAMIN B. WAGNER United States Attorney T. Zindel for J. Hitt JASON HITT Assistant U.S. Attorney
DANIEL J. BRODERICK, Bar #89424
Federal Defender
TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
Attorney for Defendant
ADRIAN REYNOSO
STIPULATION AND ORDER
CONTINUING STATUS CONFERENCE
AND EXCLUDING TIME
Time: 8:30 a.m.
Judge: Hon. William B. Shubb
IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendant, Adrian Reynoso, through their respective attorneys, that the status conference scheduled for September 12, 2011, may be continued to November 14, 2011, at 8:30 a.m.
The parties have yet to meet and confer regarding resolution of this case or to review recent medical records that may bear on that resolution. Counsel for Mr. Reynoso will be out on family medical leave for five weeks beginning next week, returning on October 17. In order to assure continuity of defense counsel and to have time to complete their discussions and the parties agree that time under the Speedy Trial Act should be excluded through November 14, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for ADRIAN REYNOSO
BENJAMIN B. WAGNER
United States Attorney
T. Zindel for J. Hitt
JASON HITT
Assistant U.S. Attorney
ORDER
The status conference is continued to November 14, 2011, at 8:30 a.m. The Court finds that time under the Speedy Trial Act shall be excluded through that date in order to afford counsel reasonable time to prepare. Based on the parties' representations, the Court finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial.
IT IS SO ORDERED.
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE