Opinion
Case No. CR.S. 2:11 0209 GEB
01-11-2012
UNITED STATES OF AMERICA, Plaintiff, v. DAVID ROMO, Defendant.
WISEMAN LAW GROUP, P.C. JOSEPH J. WISEMAN Attorney for Defendant David Romo BENJAMIN B. WAGNER United States Attorney RUSSELL L. CARLBERG Assistant U.S. Attorney Attorney for the United States
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 defendant DAVID ROMO, that the status conference presently set for January 13, 2012, be continued to February 24, 2012, at 9:00 a.m.
This stipulation is being entered into because the government intends to file additional charges in this case and will provide to the defense additional discovery related to the additional charges that will be filed in this case. The defendant and his counsel need additional time to consider and discuss the impact of the additional charges and review the additional discovery that the government intends to disclose. In any event, the government has produced or made available substantial discovery in this case and the defense requires additional time to review and digest the material.
Therefore, the UNITED STATES OF AMERICA and defendant DAVID ROMO, 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 review the forthcoming discovery and superseding indictment and determine how to best to proceed with the case) from the date of the parties' stipulation, January 13, 2012, to and including February 24, 2012.
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.
Attorney for Defendant
DAVID ROMO
UNITED STATES OF AMERICA, Plaintiff,
v.
DAVID ROMO, Defendant.
Case No. CR.S. 2:11 0209 GEB
[PROPOSED] ORDER CONTINUING STATUS CONFERENCE
Ctrm: Garland E. Burrell, Jr.
GOOD CAUSE APPEARING, it is hereby ordered that the status conference presently set for January 13, 2012 be continued to February 24, 2012 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 February 24, 2012.
IT IS SO ORDERED.
____________
Garland E. Burrell, Jr.
United States District Court Judge