Free Stipulation - District Court of California - California

Case 5:08-cr-00571-JW

Document 7

Filed 03/26/2008

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BARRY J. PORTMAN Federal Public Defender MANUEL U. ARAUJO Assistant Federal Public Defender 160 West Santa Clara Street, Suite 575 San Jose, CA 95113 Telephone: (408) 291-7753 Counsel for Defendant OCTAVIO DIAZ

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION UNITED STATES OF AMERICA, ) ) ) Plaintiff, ) ) v. ) ) OCTAVIO DIAZ, ) ) Defendant. _____________________________________ ) No. CR 08-70088- PVT STIPULATION TO EXTEND TIME FOR PRELIMINARY HEARING AND EXCLUDE TIME HON. RICHARD SEEBORG

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Defendant and the government, through their respective counsel, hereby stipulate that, subject to the court's approval, the hearing in the above-captioned matter, presently scheduled for Thursday, March 27 , 2008, at 9:30 a.m. be continued to Thursday, April 17 , 2008, at 9:30 a.m. The continuance is requested to allow time for further pre-charge negotiation and defense investigation. The parties further agree that time should be excluded under the Speedy Trial Act from March 27, 2008 to April 17, 2008, to allow time for defense investigation and preparation, and because the ends of justice outweigh the defendant's and the public's need for a speedy trial. Finally, in order to allow additional time for pre-charge negotiations, the parties also agree that time should be extended for the defendant's preliminary hearing pursuant to Federal
STIP U LA T IO N TO EX T EN D PRELIM . HEARING DATE No. CR 08-70088 PVT

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Case 5:08-cr-00571-JW

Document 7

Filed 03/26/2008

Page 2 of 2

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Rule of Criminal Procedure 5.1(d), taking into account the public interest in the prompt disposition of criminal cases.

Dated:

March 26, 2008

_________/s/________________ MANUEL U. ARAUJO Assistant Federal Public Defender _________/s/_________________ TOM O'CONNELL Assistant United States Attorney

Dated:

March 26, 2008

STIP U LA T IO N TO EX T EN D PRELIM . HEARING DATE No. CR 08-70088 PVT

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