Opinion
No. 1:11-cr-00080 AWI
01-13-2012
BENJAMIN B. WAGNER United States Attorney HENRY CARBAJAL Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender CHARLES J. LEE Assistant Federal Defender Attorney for Defendant ERIC HUGGINS
DANIEL J. BRODERICK, Bar #89424
Federal Defender
CHARLES J. LEE, Bar #221057
Assistant Federal Defender
Designated Counsel for Service
Attorney for Defendant
ERIC HUGGINS
STIPULATION AND ORDER TO CONTINUE
STATUS CONFERENCE HEARING
JUDGE: Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for January 23, 2012, may be continued to April 23, 2012 at 9:00 a.m.
This continuance is at the request of defense counsel as defense needs additional time in preparation of this case. Defense investigators have gone to the Bakersfield ICE office a total of 12 days to review 958 items of evidence, taking 2904 photographs. Defense needs additional time to evaluate the items in evidence and consider their guideline ramifications in order to properly advise Mr. Huggins. Once defense has a better understanding of the loss calculations under the guidelines, defense believe this case will reach a resolution. The requested continuance is with the intention of conserving time and resources for both parties and the court.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation and plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: Henry Carbajal
HENRY CARBAJAL
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
By: Charles J. Lee
CHARLES J. LEE
Assistant Federal Defender
Attorney for Defendant
ERIC HUGGINS
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
IT IS SO ORDERED.
____________________________
CHIEF UNITED STATES DISTRICT JUDGE