Opinion
Case No. CR.S. 2:11 0209 GEB
10-27-2011
UNITED STATES OF AMERICA, Plaintiff, v. DAVID ROMO, Defendant.
JOSEPH J. WISEMAN, ESQ., CSBN 107403 WISEMAN LAW GROUP, P.C. Attorney for Defendant DAVID ROMO
JOSEPH J. WISEMAN, ESQ., CSBN 107403
WISEMAN LAW GROUP, P.C.
Attorney for Defendant
DAVID ROMO
STIPULATION AND [PROPOSED] ORDER
CONTINUING STATUS CONFERENCE
Ctrm: Garland E. Burrell, Jr.
IT IS HEREBY STIPULATED by the parties, The UNITED STATES OF AMERICA, through undersigned counsel, Russell L. Carlberg, Assistant United States Attorney, and Joseph J. Wiseman, attorney for DAVID ROMO, that the status conference presently set for October 28, 2011 be continued to December 9, 2011 at 9:00 a.m.
Specifically, counsel has been informed that the Government will file a Superseding Indictment and will providing an additional seven boxes of discovery for review. The defendant and his counsel need additional time to review the implications of the new charges and discovery.
Therefore, the parties, the United States of America and the defendant, hereby agree and stipulate that the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendant in a speedy trial and that time under the Speedy Trial Act should therefore be excluded under 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T-4 (to allow defense counsel time to prepare, review the forensic examination, discuss plea agreement and possible resolution with government, and analyze how best to proceed with the case) from the date of the parties' stipulation, October 28, 2011, to and including December 9, 2011.
IT IS SO STIPULATED.
Respectfully submitted,
WISEMAN LAW GROUP, P.C.
By: Joseph J. Wiseman
Attorney for Defendant
David Romo
BENJAMIN B. WAGNER
United States Attorney
By: Russell L. Carlberg
Assistant U.S. Attorney
Attorney for the United States
JOSEPH J. WISEMAN, ESQ., CSBN 107403 WISEMAN LAW GROUP, P.C.
1477 Drew Avenue, Suite 106
Davis, California 95618
Telephone: 530.759.0700
Facsimile: 530.759.0800
Attorney for Defendant
DAVID ROMO
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION
UNITED STATES OF AMERICA, Plaintiff,
v.
DAVID ROMO, Defendant.
Case No. CR.S. 2:11 0209 GEB
STIPULATION AND [PROPOSED] ORDER
CONTINUING STATUS CONFERENCE
Date: December 9, 2011
Time: 9:00 a.m.
Ctrm: Garland E. Burrell, Jr.
GOOD CAUSE APPEARING, it is hereby ordered that the status conference presently set for October 28, 2011 be continued to December 9, 2011 at 9:00 a.m.
I find that the ends of justice warrant an exclusion of time and that the defendant's need for a reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 from the date of this order to December 9, 2011. IT IS SO ORDERED.
GARLAND E. BURRELL, JR.
United States District Judge