Opinion
No. 1:11-cr-00272 AWI
10-12-2011
UNITED STATES OF AMERICA, Plaintiff, v. JAVIER ROCHA-VASQUEZ, Defendant.
BENJAMIN B. WAGNER United States Attorney DATED: October 12, 2011 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 October 24, 2011, may be continued to January 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 been able to view the forensic evidence at the FBI office. We are now seeking to retain an out of state expert to test and evaluate Mr. Rocha. Defense would like to have this report completed before entering 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. The defense is requesting the amount of time it is because the experts are located in Pennsylvania and Minnesota and the coordination of schedules will be time consuming.
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
DATED: October 12, 2011
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
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 ____