IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 16, 2009
THE UNITED STATES OF AMERICA, PLAINTIFF,
SUNSHINE PASCUAL, DEFENDANT.
The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED] ORDER TO TSR VIOLATION HEARING
Time: 9:00 a.m.
IT IS HEREBY STIPULATED between the parties, Assistant United States Attorney Robin Taylor and Michael Long, attorney for SUNSHINE PASCUAL, that the status conference set for January 16, 2009, at 9:00 a.m. should be continued until February 27, 2009, at 9:00 a.m. The continuance is necessary as defense counsel is still investigating the case and the government and defense counsel are continuing to engage in negotiations.
IT IS FURTHER STIPULATED that the period of time from the signing of this Order up to and including the new status conference date of February 27, 2009, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T4, for ongoing preparation of counsel.
Dated: January 15, 2009 Respectfully submitted,
MICHAEL D. LONG Attorney for Ms. Pascual
Dated: January 15, 2009
LAWRENCE BROWN Acting United States Attorney
ROBIN TAYLOR Assistant U.S. Attorney
IT IS SO ORDERED.
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for January 16, 2009, at 9:00 a.m. be continued to February 27, 2009, at 9:00 a.m. Based on the representations of counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account due diligence. The continuance outweighs the best interests of the public and the defendants to a speedy trial. It is ordered that time from this date to February 27, 2009, shall be excluded from computation of the time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T4, to allow counsel time to prepare.
Dated: January ___, 2009 ______________________
GARLAND E. BURRELL, JR. United States District Judge
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