Filed: May 03, 2019
Latest Update: May 03, 2019
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE JOHN A. MENDEZ , District Judge . Plaintiff United States of America, through its respective counsel, and defendants Andre Ramon Washington, Roland Adrian Jufiar, and David Garcia Romero, through their counsel of record, stipulate that the status conference now set for May 7, 2019, be continued to June 25, 2019, at 9:15 a.m. On March 29, 2018, all three defendants were arraigned on the ten-count Indictment in this case. (ECF Nos. 16, 19.)
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE JOHN A. MENDEZ , District Judge . Plaintiff United States of America, through its respective counsel, and defendants Andre Ramon Washington, Roland Adrian Jufiar, and David Garcia Romero, through their counsel of record, stipulate that the status conference now set for May 7, 2019, be continued to June 25, 2019, at 9:15 a.m. On March 29, 2018, all three defendants were arraigned on the ten-count Indictment in this case. (ECF Nos. 16, 19.) ..
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
JOHN A. MENDEZ, District Judge.
Plaintiff United States of America, through its respective counsel, and defendants Andre Ramon Washington, Roland Adrian Jufiar, and David Garcia Romero, through their counsel of record, stipulate that the status conference now set for May 7, 2019, be continued to June 25, 2019, at 9:15 a.m.
On March 29, 2018, all three defendants were arraigned on the ten-count Indictment in this case. (ECF Nos. 16, 19.) In the weeks following, the government produced discovery to the defense that included over 530 pages of reports and memoranda, roughly 565 photos, and other items. In March 2019, the government produced supplemental discovery that included over 1,100 photos, forensic extraction reports for nine cellular telephones, and toll records for eleven cellular devices. Defense counsel for all three defendants require additional time to review these new materials, as well as the materials already produced, time to discuss them with their clients, to conduct research into potential suppression issues or motions to dismiss, to conduct additional investigation, and to otherwise prepare for trial.
Based on the foregoing, the parties stipulate that the status conference now set for May 7, 2019, be continued to June 25, 2019, at 9:15 a.m. The parties further agree that time under the Speedy Trial Act should be excluded from the date the parties stipulated, up to and including June 25, 2019, under 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare], and General Order 479 [Local Code T4], based on continuity of counsel and defense preparation.
The parties agree that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The parties also agree that the ends of justice served by the Court granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.
Respectfully submitted,
Dated: May 2, 2019 /s/Timothy H. Delgado
TIMOTHY H. DELGADO
Assistant United States Attorney
Attorney for Plaintiff United States
Dated: May 2, 2019 /s/ THD for David W. Dratman
DAVID W. DRATMAN
Attorney for Defendant Andre Washington
Dated: May 2, 2019 /s/ THD for Megan Virga
MEGAN VIRGA
Attorney for Defendant Roland Jufiar
Dated: May 2, 2019 /s/ THD for Ronald J. Peters
RONALD J. PETERS
Attorney for Defendant David Romero
ORDER
The Court, having received and considered the parties' stipulation, and good cause appearing therefore, adopts the parties' stipulation in its entirety as its order. The Court specifically finds that the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court also finds that the ends of justice served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.
The Court orders that the time from the date the parties stipulated, up to and including June 25, 2019, shall be excluded from computation of time within which the trial in this case must begin under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare], and General Order 479 [Local Code T4]. It is further ordered that the May 7, 2019 status conference be continued until June 25, 2019, at 9:15 a.m.
