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United States v. Boykin

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


January 7, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
ANTHONY BOYKIN AND PATRICK BOYKIN DEFENDANTS.

STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from January 5, 2009 to March 2, 2009 at 8:30 a.m.*fn1

They stipulate that the time between January 5, 2009 and March 2, 2009 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T-4. Specifically, the defendants have requested additional discovery and documentation that will potentially assist the parties in resolving this matter short of trial. The government anticipates receiving that additional discovery and documentation in the coming weeks. Defense counsel will then need additional time to review that discovery and conclude plea negotiations with the government. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(8)(A).

Respectfully Submitted, McGREGOR W. SCOTT United States Attorney

DATE: January 7, 2009

HEIKO P. COPPOLA Assistant U.S. Attorney

DATE: January 7, 2009

DWIGHT M. SAMUEL*fn2 Attorney for Defendant Patrick Boykin

DATE: December 31, 2008

Johnny L. Griffin III*fn3 Attorney for Defendant Anthony Boykin

IT IS SO ORDERED.


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