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United States v. Jones

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


September 9, 2009

THE UNITED STATES OF AMERICA PLAINTIFFS,
v.
EDMOND JONES AND RAYMOND SILLS, DEFENDANT.

STIPULATION AND ORDER TO RESET THE STATUS CONFERENCE TO SEPTEMBER 29, 2009

Defendants Edmond Jones and Raymond Sills, by and through their attorneys Krista Hart and Jay Greiner, along with the United States of America and its attorney Assistant U.S. Attorney Michael Beckwith, stipulate and agree that the status conference set for September 9, 2009, be vacated and reset to September 29, 2009, at 9:15 a.m.

The parties further stipulate and agree that the time from September 9, 2009, up to and including September 29, 2009, should be excluded in computing the time within which the trial of the above criminal prosecution must commence for purposes of 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 government and the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) (Local Code T4).

The government has provided about 20 CDs which contain more than 400 pages of discovery and numerous interviews, photographs and recordings. The defendants are continuing to review the materials and are continue to investigate the facts and circumstances of the case. Additionally, the location of the alleged incidents and the location of many, if not all the potential witnesses are outside Sacramento County. The additional time is necessary to allow counsel for the defendants to continue their work on the case.

Therefore, all parties agree the exclusion of time is necessary and appropriate.

DATED: September 11, 2009

Krista Hart Attorney for Defendant

Edmond Jones

DATED: September 11, 2009

Jay Greiner Attorney for Defendant

Raymond Sills

DATED: September 11, 2009

LAWRENCE BROWN Acting United States Attorney

Michael Beckwith Assistant U.S. Attorney

ORDER

This Court finds the ends of justice are best served by granting the request to exclude time from the Speedy Trial Act. The exclusion is necessary to allow defense counsel adequate time to review the materials and to continue to investigate the facts and circumstances of the case. This Court finds the exclusion of time from September 9, 2009, up to and including September 29, 2009, is appropriate pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4. Therefore, it is ordered that the Status Conference currently set for September 9, 2009, be vacated and reset to September 29, 2009, at 9:15 a.m. and that time is excluded.

20090909

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