Filed: May 06, 2016
Latest Update: May 06, 2016
Summary: STIPULATION AND ORDER TO STATUS CONFERENCE JOHN A. MENDEZ , District Judge . It is hereby stipulated between the parties, Paul Hemesath, Assistant United States Attorney, Michael D. Long, attorney for defendant MARIANO VALLEJO, that the status conference set for May 10, 2016, at 9:15 a.m. should be vacated and re-set for June 7, 2016, at 9:15 a.m. The parties further agree that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby
Summary: STIPULATION AND ORDER TO STATUS CONFERENCE JOHN A. MENDEZ , District Judge . It is hereby stipulated between the parties, Paul Hemesath, Assistant United States Attorney, Michael D. Long, attorney for defendant MARIANO VALLEJO, that the status conference set for May 10, 2016, at 9:15 a.m. should be vacated and re-set for June 7, 2016, at 9:15 a.m. The parties further agree that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby s..
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STIPULATION AND ORDER TO STATUS CONFERENCE
JOHN A. MENDEZ, District Judge.
It is hereby stipulated between the parties, Paul Hemesath, Assistant United States Attorney, Michael D. Long, attorney for defendant MARIANO VALLEJO, that the status conference set for May 10, 2016, at 9:15 a.m. should be vacated and re-set for June 7, 2016, at 9:15 a.m.
The parties further agree that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown. Defense counsel is still reviewing discovery, meeting with Mr. Vallejo and the prosecutors, obtaining criminal history documents, and developing defenses to the underlying criminal allegations and the criminal forfeiture allegations. Defense counsel and government counsel are continuing to engage in plea negotiations. Mr. Long is presently in a jury trial in Sacramento County Superior Court. The trial started on April 21, 2016, and it is estimated the trial will be finished on May 26, 2016.
Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Each party requests that time to be excluded as provided by Local Code T4 from today's date through June 7, 2016, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv).
All parties request the date of June 7, 2016, for the status hearing. The request for extending the date for the status conference is at the specific request of the defendant and with his knowing, intelligent and voluntary waiver of his speedy trial rights under the law. The government agrees that a continuance is necessary. Good cause is hereby shown.
Dated: May 6, 2016 Respectfully submitted,
PHIL TALBERT
Interim United States Attorney
/s/Paul Hemesath________
PAUL HEMESATH
Assistant U.S. Attorney
ORDER
GOOD CAUSE APPEARING AND HAVING BEEN SHOWN, IT IS SO ORDERED.
The date for the status hearing in this matter is hereby re-set for June 7, 2016, at 9:15 a.m., before District Court Judge John A. Mendez. The court finds that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Time is excluded as provided by Local Code T4 from today's date through June 7, 2016, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv). No further continuances should be requested until the parties appear on May 6, 2016
