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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 Case 2:06-cr-00170-WBS Document 33 Filed 08/09/06 Page 1 of 4 1 McGREGOR W. SCOTT United States Attorney 2 WILLIAM S. WONG Assistant U.S. Attorney 3 501 "I" Street, Suite 10-100 Sacramento, California 95814 4 Telephone: (916) 554-2790 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 UNITED STATES OF AMERICA, ) ) CR S-06-0170 WBS 12 Plaintiff, ) ) STIPULATION AND ORDER RESETTING 13 v. ) STATUS CONFERENCE, AND EXCLUDING ) TIME UNDER THE SPEEDY TRIAL ACT 14 ONOFRE SOTO ZUNIGA, and ) MINERVA CAMPOS, ) 15 ) Defendants. ) 16 _____________________________) 17 The United States of America, through its counsels of record, 18 McGregor W. Scott, United States Attorney for the Eastern District 19 of California, and William S. Wong, Assistant United States 20 Attorney, and defendant Onofre Soto Zuniga, through his counsel of 21 record, Terance Hallinan, Esq., and defendant Minerva Campos, 22 through her counsel of record, Kevin McLean, Esq., hereby submit 23 this stipulation and proposed order resetting the status conference 24 on August 2, 2006 to September 20, 2006. 25 Counsel for the government submits this stipulation and order 26 at the request of defendant Onofre Soto Zuniga’s counsel, Terance 27 Hallinan, as a courtesy for out-of-town counsel. The request to 28 continue the status conference is made at the request of Terence 1 Case 2:06-cr-00170-WBS Document 33 Filed 08/09/06 Page 2 of 4 1 Hallinan, counsel for defendant Onofre Soto Zuniga on the grounds 2 that counsel needs additional time to investigate and prepare a 3 legal defense for the defendant. Additionally, Kevin McLean, 4 counsel for defendant Minerva Campos, is engaging in additional 5 discovery investigation with government’s counsel. 6 Counsel for the government and the defense are actively 7 negotiating a possible resolution to this matter and require 8 additional time. 9 All counsels request that time be excluded from August 2, 2006, 10 to September 20, 2006, from computation of time within which the 11 trial of this case must be commenced pursuant to 18 U.S.C. 12 § 3161(h)(8)(B)(iv) and Local Code T4 (to give defense counsels 13 reasonable time to prepare). 14 IT IS SO STIPULATED. 15 McGREGOR W. SCOTT United States Attorney 16 Dated: August 2, 2006 By: /s/ William S. Wong 17 WILLIAM S. WONG Assistant U.S. Attorney 18 Attorneys for Plaintiff 19 DATED: August 2, 2006 By: /s/ Terence Hallinan TERENCE HALLINAN 20 Attorney for Defendant ONOFRE SOTO ZUNIGA 21 DATED: August 2, 2006 By: /s/ Kevin McLean 22 KEVIN McLEAN Attorney for Defendant 23 MINERVA CAMPOS 24 ________________________________________________________________ 25 ORDER 26 UPON GOOD CAUSE SHOWN and by stipulation of all parties, it is 27 hereby ordered that the status conference be continued as set forth 28 /// 2 Case 2:06-cr-00170-WBS Document 33 Filed 08/09/06 Page 3 of 4 1 above and that this matter be set for further status conference on 2 September 20, 2006. 3 The Court finds excludable time as set forth above to and 4 including September 20, 2006. 5 IT IS SO ORDERED. 6 7 DATED: August 7, 2006 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Case 2:06-cr-00170-WBS Document 33 Filed 08/09/06 Page 4 of 4 1 2 CERTIFICATE OF SERVICE BY MAIL 3 The undersigned hereby certifies that she is an employee in the 4 Office of the United States Attorney for the Eastern District of 5 California and is a person of such age and discretion to be 6 competent to serve papers; that on AUGUST 2, 2006, she served a copy 7 of STIPULATION AND ORDER RESETTING STATUS CONFERENCE, AND EXCLUDING 8 TIME UNDER THE SPEEDY TRIAL ACT by placing said copy in a postpaid 9 envelope addressed to the persons hereinafter named, at the places 10 and addresses stated below, which are the last known addresses, and 11 by depositing said envelope and its contents in the United States 12 Mail at Sacramento, California. 13 Addressees: 14 Terence Hallinan, Esq. Kevin McLean, Esq. 15 Law Office of Terence Hallinan Belli & McLean 819 Eddy Street 473 Jackson Street, 2nd Flr. 16 San Francisco, CA 94109 San Francisco, CA 94111 17 18 19 LORI WHITMER 20 21 22 23 24 25 26 27 28 4.
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