Opinion
Case No. 1:11-cr-00242 LJO
10-27-2011
UNITED STATES OF AMERICA, Plaintiff, v. DANIEL VASQUEZ-MIRANDA and ZOILA VAZQUEZ-VAZQUEZ, Defendants.
BENJAMIN B. WAGNER United States Attorney IAN L. GARRIQUES Assistant U.S. Attorney JEREMY S. KROGER Attorney for Defendant DANIEL VASQUEZ-MIRANDA KATHERINE L. HART Attorney for Defendant ZOILA VAZQUEZ-VAZQUEZ
BENJAMIN B. WAGNER
United States Attorney
IAN L. GARRIQUES
Assistant U.S. Attorney
Attorneys for the
United States of America
STIPULATION TO CONTINUE STATUS CONFERENCE; [PROPOSED] ORDER
Judge: Hon. Lawrence J. O'Neill
IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective attorneys of record herein, that the status conference now set for October 28, 2011, may be continued to November 14, 2011, at 1:00 p.m.
The reason for the continuance is to allow for further case preparation, investigation, and plea negotiations. Specifically, the parties reached a tentative oral agreement this afternoon, which needs to be reduced to writing. The continuance is necessary to allow the government to prepare and send a new written offer to defendants and for time for defense counsel to review the revised offers with defendants. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial and that the delay from the continuance shall be excluded from the calculation of time under the Speedy Trial Act pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: IAN L. GARRIQUES
Assistant U.S. Attorney
By: JEREMY S. KROGER
Attorney for Defendant
DANIEL VASQUEZ-MIRANDA
By: KATHERINE L. HART
Attorney for Defendant
ZOILA VAZQUEZ-VAZQUEZ
ORDER
The intervening period of delay shall be excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(iv).
IT IS SO ORDERED.
Lawrence J. O'Neill
UNITED STATES DISTRICT JUDGE