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United States v. Gervolstad

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


August 28, 2009

UNITED STATE OF AMERICA PLAINTIFF,
v.
JOSHUA GERVOLSTAD DEFENDANT.

STIPULATION AND PROPOSED ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from August 31, 2009 to September 21, 2009 at 8:30 a.m.. They stipulate that the time between August 31, 2009 and September 21, 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). Specifically, the parties anticipate further analysis of Defendant's criminal history and its impact on the sentencing guidelines with regard to this Defendant particularly. 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. § (h) (8) (A).

Respectfully Submitted,

Date: August 27, 2009

Matt Segal_by SSC MATTHEW D. SEGAL Assistant U.S. Attorney

SO ORDERED.

20090828

© 1992-2009 VersusLaw Inc.



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