Opinion
Law Offices of Ron Peters RON PETERS, Sacramento, California Attorney for Defendant ABRAHAM VALDEZ
BENJAMIN B. WAGNER, United States Attorney, JILL THOMAS, Assistant U.S. Attorney,
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., District Judge.
The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Jill Thomas, Assistant United States Attorney, and defendant Abraham Valdez, through his attorney, Ronald Peters, Esq, hereby stipulate and agree that the status conference scheduled for November 6, 2015 at 9:00 am should be continued to December 17, 2015 at 9:00 a.m.
Defendant's attorney has a conflict in State Superior Court that was scheduled after the last continuance. Accordingly, a Local Rule T-4 exclusion would be appropriate and preparation and continuity of counsel.
Parties agree that time should be excluded pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv), and Local Code T-4 - reasonable time to prepare and for continuity of counsel. The parties agree that time be excluded under this provision from November 6, 2015 to and including December 17, 2015.
ORDER
The Court, having considered the stipulation of the parties, and good cause appearing therefrom, adopts that stipulation in its entirety as its order. Based on the stipulation of the parties, the Court finds that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and defendant continuity of counsel. The Court specifically finds that the ends of justice served by the granting of such continuance outweigh the interests of the public and that the time from the date of the stipulation, November 6, 2015, to and including December 17, 2015.
IT IS SO ORDERED.