U.S. v. Rangel, 2:15-CR-093 GEB. (2017)
Court: District Court, E.D. California
Number: infdco20170123556
Visitors: 20
Filed: Jan. 19, 2017
Latest Update: Jan. 19, 2017
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT GARLAND E. BURRELL, Jr. , District Judge . This matter is presently set for a status conference before the Court on January 20, 2017. The parties to this action, Plaintiff United States of America by and through Assistant United States Attorney Jason Hitt, and Defendant Alex Velasquez Rangel (a.k.a. Juan Serrano Garcia) by and through his attorney Todd D. Leras, stipulate as follows:
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT GARLAND E. BURRELL, Jr. , District Judge . This matter is presently set for a status conference before the Court on January 20, 2017. The parties to this action, Plaintiff United States of America by and through Assistant United States Attorney Jason Hitt, and Defendant Alex Velasquez Rangel (a.k.a. Juan Serrano Garcia) by and through his attorney Todd D. Leras, stipulate as follows: ..
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STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
GARLAND E. BURRELL, Jr., District Judge.
This matter is presently set for a status conference before the Court on January 20, 2017. The parties to this action, Plaintiff United States of America by and through Assistant United States Attorney Jason Hitt, and Defendant Alex Velasquez Rangel (a.k.a. Juan Serrano Garcia) by and through his attorney Todd D. Leras, stipulate as follows:
1. By previous order, this matter was set for a status conference on January 20, 2017.
2. By this stipulation, Defendant now moves to continue the status conference to May 12, 2017, at 9:00 a.m., and to exclude time between January 20, 2017 and May 12, 2017, under Local Code T-4. The United States does not oppose this request.
3. The parties agree and stipulate, and therefore request, the Court find the following:
a.) The discovery in the case consists of 293 Bates stamped items, including audio recordings, videos, and several spreadsheets of phone data and text messages. All discovery has either been made available to counsel directly or through inspection and copying.
b.) Counsel for Defendant desires additional time to conduct defense investigation into this case and its relationship to another case related under Docket #53. Defendant requires the assistance of a Spanish interpreter to review all discovery and discuss the additional defense investigation into this matter and the related matter.
c.) Defense counsel believes that failure to grant additional time as requested would deny him the reasonable time necessary for effective preparation, taking into consideration counsel's exercise of due diligence.
4. Based on the above-stated facts, the parties jointly request that the Court find that the ends of justice served by continuing the case as requested outweigh the best interest of the public and the Defendant in a trial within the time prescribed by the Speedy Trial Act.
5. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of January 20, 2017 to May 12, 2017, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(A), and (B) (iv) [Local Code T-4] because it results from a continuance granted by the Court at Defendant's request on the basis that the ends of justice served by taking such action outweigh the best interest of the public and the Defendant in a speedy trial.
6. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.
IT IS SO STIPULATED.
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
Source: Leagle
