Filed: Sep. 12, 2014
Latest Update: Sep. 12, 2014
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Olusere Olowoyeye, defendant, Carlos Cortez, by and through his counsel, Douglas Beevers, and defendant, Ismael Ramirez, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, September 16, 2014 at 9:30 a.m., in the above-captioned matter, and to
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Olusere Olowoyeye, defendant, Carlos Cortez, by and through his counsel, Douglas Beevers, and defendant, Ismael Ramirez, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, September 16, 2014 at 9:30 a.m., in the above-captioned matter, and to c..
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
JOHN A. MENDEZ, District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Olusere Olowoyeye, defendant, Carlos Cortez, by and through his counsel, Douglas Beevers, and defendant, Ismael Ramirez, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, September 16, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to November 18, 2014 at 9:30 a.m. in the courtroom of the Honorable John A. Mendez.
The reason for this request is to allow time for the defense to complete review of discovery and other defense preparation, and for the parties to engage in plea negotiations. The Court is advised that Mr. Olowoyeye concurs with this request and that he and Mr. Beevers 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 November 18, 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
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of September 16, 2014 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on November 18, 2014 at 9:30 a.m. The Court finds excludable time in this matter through November 18, 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.
