The opinion of the court was delivered by: Judge Hon. Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS HEARING
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 February 27, 2009, at 9:00 a.m. should be continued until March 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 settlement 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 March 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.
MICHAEL D. LONG Attorney for Ms. Pascual
LAWRENCE BROWN Acting United States Attorney ROBIN TAYLOR Assistant U.S. Attorney
MICHAEL D. LONG (CA State Bar #149475) 901 H Street, Suite 208 Sacramento, CA 95814 (916) 447-1920 Long_5999@msn.com
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for February 27, 2009, at 9:00 a.m. be continued to March 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 March 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.
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