Opinion
No. CRS 11-346 JAM
10-27-2011
DINA L. SANTOS Attorney for Defendant SERGIO ALVAREZ-MAGANA MICHAEL PETRIK Attorney for Defendant MARGARITO VIDRO-GONZALEZ HEIKO COPPOLA Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
A Professional Law Corporation
Attorney for Defendant
SERGIO ALVAREZ MAGANA
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
Judge: Hon. JOHN A. MENDEZ
IT IS HEREBY STIPULATED by and between Assistant United States Attorney HEIKO COPPOLA, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant SERGIO ALVAREZ-MAGANA, and Attorney MICHAEL PETRIK, Counsel for Defendant MARGARITO VIDRO-GONZALEZ, that the status conference scheduled for November 1, 2011, be vacated and the matter be continued to this Court's criminal calendar on December 13, 2011, at 9:30 a.m., for further status and possible change of plea.
This continuance is requested by the defense in order to permit further negotiations with the government, and to continue in client consultations concerning available courses of action. The defense and prosecution require more time to negotiate the terms of the plea agreement and the Defense needs time to review the plea agreement with the clients using a certified Spanish interpreter.
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 December 13, 2011 date, and that all counsel have authorized Ms. Santos to sign this stipulation on their behalf.
IT IS SO STIPULATED.
DINA L. SANTOS
Attorney for Defendant
SERGIO ALVAREZ-MAGANA
MICHAEL PETRIK
Attorney for Defendant
MARGARITO VIDRO-GONZALEZ
HEIKO COPPOLA
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
By the Court,
Hon. John A. Mendez
United States District Judge