Free Stipulation - District Court of California - California

Case 4:07-cr-00600-SBA

Document 17

Filed 03/14/2008

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JOSEPH P. RUSSONIELLO (CABN 44332) United States Attorney BRIAN J. STRETCH (CABN 163973) Chief, Criminal Division JAMES C. MANN (CABN 221603) Assistant United States Attorneys 1301 Clay Street, Suite 340-S Oakland, California 94612 Telephone: (510) 637-3680 Facsimile: (510) 637-3724 E-Mail: [email protected] Attorneys for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION UNITED STATES OF AMERICA, Plaintiff, v. SERGIO LERMA-LOPEZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) No. CR-07-00600 SBA STIPULATED REQUEST TO CONTINUE HEARING DATE TO APRIL 8, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: March 18, 2008 9:00 a.m. Hon. Saundra Brown Armstrong

The above-captioned matter was set on March 18, 2008 before this Court for status or change of plea. The parties request that this Court continue the hearing to April 8, 2008 at 9:00 a.m. and that the Court exclude time under the Speedy Trial Act between the date of this stipulation and April 8, 2008. The government has requested certain documents relevant to Defendant's criminal history. The government has been informed that the documents will not be available until March 26, 2008. Additionally, counsel for the government is out of the state from March 31, 2008 through April 4, 2008. Therefore, the parties stipulate and request that the Court exclude time between the date of this stipulation and April 8, 2008 under the Speedy Trial Act for effective preparation of counsel and continuity of government counsel pursuant to 18 U.S.C. §
STIP. REQ. TO SET CONTINUE HEARING TO APRIL 8, 2008 AND TO EXCLUDE TIM E No. CR-07-00600 SBA

Case 4:07-cr-00600-SBA

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3161(h)(8)(B)(iv). The parties agree the ends of justice served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial.

DATED: March 14, 2008

/s/ JAMES C. MANN Assistant United States Attorney Counsel for United States

/s/ JOYCE LEAVITT Counsel for Sergio Lerma-Lopez

STIP. REQ. TO SET CONTINUE HEARING TO APRIL 8, 2008 AND TO EXCLUDE TIM E No. CR-07-00600 SBA

Case 4:07-cr-00600-SBA

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The parties jointly requested that the hearing in this matter be continued from March 18, 2008 to April 8, 2008, and that time be excluded under the Speedy Trial Act between March 14, 2008 and April 8, 2008 to allow for the effective preparation of counsel and continuity of government counsel for the reasons set forth in the parties' stipulated request. For these stated reasons, the Court finds that the ends of justice served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial. Good cause appearing therefor, and pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv), IT IS HEREBY ORDERED that this matter is set for status or change of plea on April 8, 2008 at 9:00 a.m., and that time between March 14, 2008 and April 8, 2008 is excluded under ////
STIP. REQ. TO SET CONTINUE HEARING TO APRIL 8, 2008 AND TO EXCLUDE TIM E No. CR-07-00600 SBA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION UNITED STATES OF AMERICA, Plaintiff, v. SERGIO LERMA-LOPEZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) No. CR-07-00600 SBA STIPULATED REQUEST TO CONTINUE HEARING DATE TO APRIL 8, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: March 18, 2008 9:00 a.m. Hon. Saundra Brown Armstrong

Case 4:07-cr-00600-SBA

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the Speedy Trial Act to allow for the effective preparation of counsel, taking into account the exercise of due diligence.

DATED:_________________

____________________________________ HON. SAUNDRA BROWN ARMSTRONG United States District Judge

STIP. REQ. TO SET CONTINUE HEARING TO APRIL 8, 2008 AND TO EXCLUDE TIM E No. CR-07-00600 SBA