Opinion
No. 1:11-cr-00272 AWI
01-13-2012
UNITED STATES OF AMERICA, Plaintiff, v. JAVIER ROCHA-VASQUEZ, Defendant.
BENJAMIN B. WAGNER United States Attorney JEREMY JEHANGIRI Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender CHARLES J. LEE Assistant Federal Defender Attorney for Defendant JAVIER ROCHA-VASQUEZ
DANIEL J. BRODERICK, Bar #89424
Federal Defender
CHARLES J. LEE, Bar #221057
Assistant Federal Defender
Designated Counsel for Service
Attorney for Defendant
JAVIER ROCHA-VASQUEZ
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE HEARING
JUDGE: Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for January 23, 2012, may be continued to April 23, 2012 at 9:00 A.M.
This continuance is at the request of defense counsel to allow time for proper preparation of the case. Defense counsel has retained an expert who has come out from Minnesota to meet with and interview Mr. Rocha. However, additional time is necessary for the expert to complete her evaluation and her report. Defense would like this report before pursuing plea negotiations with the government. In order to properly prepare the case, defense is requesting the additional time. The requested continuance will serve the ends of justice and result in economic use of time and resources and will conserve time and resources for all parties and the court.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation and for plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: Jeremy Jehangiri
JEREMY JEHANGIRI
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
By: Charles J. Lee
CHARLES J. LEE
Assistant Federal Defender
Attorney for Defendant
JAVIER ROCHA-VASQUEZ
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
IT IS SO ORDERED.
____________________________
CHIEF UNITED STATES DISTRICT JUDGE