Filed: Oct. 18, 2019
Latest Update: Oct. 18, 2019
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION The defendant, Georgina Lopez-Quintero, by and through her counsel, Toni White, Cesar Erendira Nava, by and through his counsel, Clemente Jimenez, Alfonso Rivera, Jr., by and through his counsel, Jason Michael Lawley, Gary M. Roberts, by and through is counsel, Etan Zaitsu, and the Government, by and through its counsel, Jason Hitt, hereby stipulate as follows: 1. By pr
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION The defendant, Georgina Lopez-Quintero, by and through her counsel, Toni White, Cesar Erendira Nava, by and through his counsel, Clemente Jimenez, Alfonso Rivera, Jr., by and through his counsel, Jason Michael Lawley, Gary M. Roberts, by and through is counsel, Etan Zaitsu, and the Government, by and through its counsel, Jason Hitt, hereby stipulate as follows: 1. By pre..
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STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER
JOHN A. MENDEZ, District Judge.
STIPULATION
The defendant, Georgina Lopez-Quintero, by and through her counsel, Toni White, Cesar Erendira Nava, by and through his counsel, Clemente Jimenez, Alfonso Rivera, Jr., by and through his counsel, Jason Michael Lawley, Gary M. Roberts, by and through is counsel, Etan Zaitsu, and the Government, by and through its counsel, Jason Hitt, hereby stipulate as follows:
1. By previous order, this matter was set for status on October 22, 2019
2. By this stipulation, the above-named defendants now move to continue the status conference until January 14, 2020 at 9:15 a.m., and to exclude time between October 22, 2019, and January 14, 2020, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) Ms. White was substituted in as counsel for Ms. Lopez-Quintero on September 24, 2019 and needs time to review discovery.
b) Discovery in this case consists of hundreds of pages of investigative reports, multiple wiretap applications, audio recordings of thousands of intercepted calls, transcripts, photographs, video and seized real evidence. All of this discovery has been discovered or made available to defense counsel.
c) Defense counsels need additional time to continue to review discovery, to continue to consult with their clients, review the current charges, conduct investigation and research related to the charges and to discuss potential resolutions with their clients and otherwise prepare for trial.
d) Defense counsels believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
e) The Government does not object to the continuance.
f) Based on the above-stated findings, 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.
g) 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 October 22, 2019 to January 14, 2020, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendants' request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendants in a speedy trial.
4. 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.
DATED: October 18, 2019
By Toni White for
JASON HITT
Assistant United States Attorney
DATED: October 18, 2019
By /s/Toni White
CLEMENTE JIMENEZ
Attorney for Defendant
CESAR ERENDIRA NAVA
DATED: October 18, 2019
By /s/Toni White for
MICHAEL JASON LAWLEY
Attorney for Defendant
ALFONSO RIVERA JR.
DATED: October 18, 2019
By /s/Toni White for
ETAN ZAITSU
Attorney for Defendant
GARY M. ROBERTS
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
