Opinion
No. CR-S 11-487 JAM
07-09-2012
UNITED STATES OF AMERICA, Plaintiff, v. JOSE RODRIGUEZ-LOPEZ Defendant.
DINA L. SANTOS Attorney for Jose Rodriguez-Lopez JARED DOLAN Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
A Professional Law Corporation
428 J Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 447-0160
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 July 10, 2012, be vacated and the matter be continued to this Court's criminal calendar on August 7, 2012, at 9:45 a.m. for further status and possible change of plea.
This continuance is requested by the defense in order to permit the Government time to verify and follow up on information provided by the defense that is necessary to reach a plea agreement. The Defense continues to review discovery and negotiate with the Government.
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 August 7, 2012, date, and that Mr. Dolan has authorized Ms. Santos to sign this stipulation on his behalf.
IT IS SO STIPULATED.
______________
DINA L. SANTOS
Attorney for
Jose Rodriguez-Lopez
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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
Stipulation and Order