Filed: Mar. 17, 2014
Latest Update: Mar. 17, 2014
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE MORRISON C. ENGLAND, Jr., Chief District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Michele M. Beckwith, defendant, Edwin Malo-Vergara, by and through his counsel, David W. Bonilla, defendant, Jose Junez-Ramirez, Sr., by and through his counsel, Kyle R. Knapp, and defendant, Ruben Aurelio Bulgin, by and through his counsel, Erin J. Radekin, agree and stipulate to vacat
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE MORRISON C. ENGLAND, Jr., Chief District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Michele M. Beckwith, defendant, Edwin Malo-Vergara, by and through his counsel, David W. Bonilla, defendant, Jose Junez-Ramirez, Sr., by and through his counsel, Kyle R. Knapp, and defendant, Ruben Aurelio Bulgin, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate..
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., Chief District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Michele M. Beckwith, defendant, Edwin Malo-Vergara, by and through his counsel, David W. Bonilla, defendant, Jose Junez-Ramirez, Sr., by and through his counsel, Kyle R. Knapp, and defendant, Ruben Aurelio Bulgin, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, March 20, 2014 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to May 8, 2014 at 9:00 a.m. in the courtroom of the Honorable Morrison C. England, Jr.
The reason for this request is that the defense needs additional time to complete investigation, other defense preparation, and plea negotiations. The Court is advised that Ms. Beckwith concurs with this request and all counsel set forth above 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 May 8, 2014 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 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.
Dated: March 13, 2014 BENJAMIN WAGNER
United States Attorney
By: /s/ Michele Beckwith
MICHELE BECKWITH
Assistant United States Attorney
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of March 20, 2014 at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on May 8, 2014 at 9:00 a.m. The Court finds excludable time in this matter through May 8, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, 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.
