Opinion
No. CR-S 11-487 JAM
01-18-2012
UNITED STATES OF AMERICA, Plaintiff, v. JOSE RODRIGUEZ-LOPEZ Defendant.
DINA L. SANTOS, Bar #204200 A Professional Law Corporation Attorney for Defendant JOSE RODRIGUEZ-LOPEZ
DINA L. SANTOS, Bar #204200
A Professional Law Corporation
Attorney for Defendant
JOSE RODRIGUEZ-LOPEZ
STIPULATION AND ORDER VACATING
DATE, CONTINUING CASE, AND EXCLUDING TIME
Judge: Hon. Mendez
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Jared Dolan, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant Jose Rodriguez-Lopez, that the status conference scheduled for January 24, 2012, be vacated and the matter be continued to this Court's criminal calendar on February 28, 2012, at 9:30 a.m. for further status.
This continuance is requested by the defense in order to permit counsel to conduct investigation, review discovery, and engage in negotiations with the prosecution in attempt to reach a plea agreement.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.
The Court is advised that all counsel have conferred about this request, that they have agreed to the February 28, 2012, date, and that Mr. Dolan has authorized Ms. Santos to sign this stipulation on his behalf.
IT IS SO STIPULATED.
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DINA L. SANTOS
Attorney for
Raymundo Ramos
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JARED DOLAN
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
By the Court,
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Hon. John A. Mendez
United States District Court Judge