STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY STIPULATED by and between Plaintiff United States of America, by and through Acting United States Attorney Lawrence G. Brown and Assistant United States Attorney Todd D. Leras, and Attorney Jesse Santana, Counsel for Defendant James Keith Fletcher, Attorney David Vasquez, Counsel for Defendant Tori Michelle Stohlman and Attorney Roberto Marquez, Counsel for Defendant Kyle Leonard, that the status conference scheduled for June 23, 2009, be continued to August 18, 2009, at 9:15 a.m.
The request to continue the status conference is made on the ground that additional time is needed to negotiate possible settlement of the case. All defense counsel met for negotiations with the government on June 12, 2009. The parties have scheduled two additional meetings in July to conduct further negotiations. The additional time is needed for attorney preparation for the meetings. The government and all defendants agree that an exclusion of time is appropriate under 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4 (reasonable time to prepare). This exclusion of time includes the period from July 23, 2009, up to and including August 18, 2009.
Defense counsel have authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on their behalf.
By: TODD D. LERAS Assistant U.S. Attorney
By: Todd D. Leras for JESSE I. SANTANA Attorney for Defendant JAMES KEITH FLETCHER
By: Todd D. Leras for DAVID VASQUEZ Attorney for Defendant TORI MICHELLE STOHLMAN
By: Todd D. Leras for ROBERTO MARQUEZ Attorney for Defendant KYLE LEONARD
1. The status conference set for June 23, 2009, is continued to August 18, 2009, at 9:15 a.m.
2. Based on the stipulations and representations, the Court finds that the ends of justice outweigh the best interest of the public and Defendants in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T4 ...