Filed: Jul. 15, 2019
Latest Update: Jul. 15, 2019
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE AND CONVERT TO CHANGE OF PLEA HEARING JOHN A. MENDEZ , District Judge . IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through Mira Chernick, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Mr. Valdez-Mendoza, that the status conference currently set for July 16, 2019 may b
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE AND CONVERT TO CHANGE OF PLEA HEARING JOHN A. MENDEZ , District Judge . IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through Mira Chernick, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Mr. Valdez-Mendoza, that the status conference currently set for July 16, 2019 may be..
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE AND CONVERT TO CHANGE OF PLEA HEARING
JOHN A. MENDEZ, District Judge.
IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through Mira Chernick, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Mr. Valdez-Mendoza, that the status conference currently set for July 16, 2019 may be converted to a Change of Plea hearing and set for August 13, 2019.
The parties have recently agreed to a resolution in this matter and are therefore requesting a Change of Plea hearing. The parties further request an exclusion of time from July 16, 2019 to August 13, 2019 under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(H)(7)(A) and (B)(iv) (Local Code "T4"). The government has produced approximately 511 pages of discovery, which the defense requires time to review in order to prepare a defense should the Change of Plea not be completed as planned, and for sentencing purposes. The parties therefore respectfully request the Court to find that the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act, and to exclude time from July 16, 2019 to August 13, 2019 pursuant to Local Code T4.
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.
Respectfully submitted,
HEATHER E. WILLIAMS
Federal Defender
Date: July 15, 2019 /s/ Christina Sinha
CHRISTINA SINHA
Assistant Federal Defender
Attorneys for Defendant
CARLOS VALDEZ-MENDOZA
Date: July 15, 2019 MCGREGOR W. SCOTT
United States Attorney
/s/ Mira Chernick
MIRA CHERNICK
Assistant United States Attorney
Attorney for Plaintiff
ORDER
The Court, having received and considered the parties' stipulation, and good cause appearing therefrom, adopts the parties' stipulation in its entirety as its order. The status conference currently set for July 16, 2019 is hereby reset for August 13, 2019, and is converted to a Change of Plea hearing. The time period of July 16, 2019 to August 13, 2019, inclusive, is deemed excludable under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(H)(7)(A) and (B)(iv) (Local Code "T4").
IT IS SO ORDERED.
