UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
February 11, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
PANFILO VENEGAS-VENEGAS, DEFENDANT.
The opinion of the court was delivered by: Marilyn H. Patel United States District Court Judge
STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME UNDER 18 U.S.C. § 3161
The parties are scheduled to appear again before the Court on February 9, 2009 for a change of plea. At the prior status conference on February 2, 2009, the Court agreed to exclude all time under the Speedy Trial Act between February 2, 2009 and February 9, 2009 for continuity of counsel. 18 U.S.C. § 3161(h)(8)(B)(iv). The parties and Court agreed that the ends of justice served by granting such a continuance for continuity of counsel outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(8)(A). Based on the exclusion of time through February 9, 2009, defendant's speedy trial date will be April 20, 2009.
JOSEPH P. RUSSONIELLO United States Attorney
DATED February 5, 2009
KATHERINE B. DOWLING Assistant United States Attorney
JODI LINKER Attorney for Defendant
Failure to grant an exclusion of time for the requested continuance would deny counsel for defendant reasonable time necessary for continuity of counsel. 18 U.S.C. § 3161(h)(8)(B)(iv).
Therefore, the Court finds that exclusion of time from February 2, 2009 through February 9, 2009, is warranted because the ends of justice served by the exclusion of time outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(8)(A).
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