Opinion
No. 1:11-cr-00272 AWI
08-30-2011
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 September 6, 2011, may be continued to October 24, 2011 at 9:00 A.M.
This continuance is at the request of defense counsel to allow time for proper preparation of the case. This is the first status conference and defense needs additional time to review the discovery, view the evidence, and meet with the client. Defense also requests additional time to enter into plea negotiations with the government. 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. Assistant United States Attorney Jeremy Jehangiri has no objection to this request.
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
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
By: 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.
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CHIEF UNITED STATES DISTRICT JUDGE