United Statesv.Galvan

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIAAug 6, 2012
2:12-CR-00115 GEB (E.D. Cal. Aug. 6, 2012)

2:12-CR-00115 GEB

08-06-2012

UNITED STATES OF AMERICA, Plaintiff, v. ALEJANDRO MUNOZ GALVAN, et al., Defendants.

BENJAMIN WAGNER United States Attorney TODD LERAS Assistant United States Attorney SHARI RUSK Attorney for Defendant GARARDO CARDENAS MICHAEL BIGELOW Attorney for Defendant ALEJANDRO PANTOJA-SOLORIO ERIN J. RADEKIN Attorney for Defendant ALEJANDRO MUNOZ GALVAN


ERIN J. RADEKIN


Attorney at Law - SBN 214964


Attorney for Defendant


ALEJANDRO MUNOZ GALVAN


STIPULATION AND [PROPOSED] ORDER

TO CONTINUE STATUS CONFERENCE


STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Todd Leras, defendant, Alejandro Pantoja-Solorio, by and through his counsel, Michael Bigelow, defendant Garardo Cardenas, by and through his counsel, Shari Rusk, and defendant Alejandro Munoz Galvan, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, August 10, 2012 at 9:00 a.m., and to continue the status conference to September 21, 2012 at 9:00 a.m. in the courtroom of the Honorable Garland E. Burrell, Jr.

The reason for this request is that the parties need additional time to review discovery and for other defense preparation. The Court is advised that all counsel named above concur with this request and have authorized Ms. Radekin to sign this stipulation on their behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until September 21, 2012 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation. IT IS SO STIPULATED

BENJAMIN WAGNER


United States Attorney


By:_________


TODD LERAS


Assistant United States Attorney


___________


SHARI RUSK


Attorney for Defendant


GARARDO CARDENAS


___________


MICHAEL BIGELOW


Attorney for Defendant


ALEJANDRO PANTOJA-SOLORIO


_________


ERIN J. RADEKIN


Attorney for Defendant


ALEJANDRO MUNOZ GALVAN


ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference of August 10, 2012 at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on September 21, 2012 at 9:00 a.m. The court finds excludable time in this matter through September 21, 2012 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. 3161(h)(7)(A), (h)(7)(B)(iv). IT IS SO ORDERED.

__________


GARLAND E. BURRELL, JR.


Senior United States District Judge